We have a recognised track record in corporate criminal liability work. We have extensive experience of SFO-led corruption inquiries as well as international corruption and sanctions investigations.
We advise clients:
- in relation to corruption and sanctions investigations, including advising on a client’s self-reporting obligations and potential criminal and civil liability
- on anti-corruption compliance, including under the Bribery Act 2010
- on issues arising under the Fraud Act, the Proceeds of Crime Act, and various sanctions and export control regimes
Our expertise is in high-profile, complex, technically-demanding work across a broad range of business sectors. On the transaction side, we understand well the criminal law issues which can arise in the context of corporate M&A work, eg in relation to transactions involving criminal property.
We are known for our experience of criminal and quasi-criminal investigations with cross-border implications where we work alongside our network of 'Best Friend' firms. In the field of trade and financial sanctions matters, we have a sound insight into, and understanding of, the requests and requirements of the various regulators worldwide.
'… its meticulous and detailed approach is applauded' Chambers UK, 2010View all Global Investigations media comments
Our key experience includes advising:
Olympus in relation to investigations by regulators in several jurisdictions into certain transactions entered into by Olympus which are now thought to have been part of a scheme (known as a 'tobashi' scheme) used to hide investment losses over a number of years.
Standard Chartered (SCB) in relation to its agreements with the US Department of Justice, the New York County District Attorney's Office, the Federal Reserve Bank of New York, and Office of Foreign Assets Control, which include a total penalty of US$327 million announced on 10 December 2012, and SCB's agreement in August 2012 with the New York State Department of Financial Services, in relation to the same global sanctions investigation, pursuant to which SCB agreed to pay a civil money penalty of US$340 million.
GSK in relation to sanctions and corruption investigations by the UK (SFO) and US (SEC and Department of Justice) law enforcement bodies into the supply of goods into Iraq under the UN Oil-for-Food programme.
Diageo in relation to an overseas corruption investigation spanning multiple jurisdictions (including Korea, Thailand and India) and regulators, including liaising with overseas lawyers regarding settlement of the case in the US with the US Securities and Exchange Commission, and the impact of that on relations with the SFO.
an international pharmaceuticals group in relation to an investigation by the SFO into alleged fraudulent invoicing and a related investigation by HMRC into alleged VAT evasion.
a global financial institution and a major African financial institution on a variety of complex issues arising out of the Zimbabwe sanctions regime, including advising the global financial institution in relation to threatened enforcement action by the English government in respect of alleged breaches of that regime.
a criminal investigation and subsequent prosecution by the Securities and Futures Commission of alleged insider dealing by the former director of a listed company.
a criminal investigation by the Independent Commission Against Corruption into allegations regarding corrupt payments and subsequent trial involving employees of a listed company.
a global provider of offshore services on the UK aspects of an international bribery investigation, including allegations of bribery in Nigeria.