This week the (legislative) Bill to amend the UK’s Modern Slavery Act 2015 reached the committee stage in the UK’s House of Lords. No changes were suggested to the Bill so it now goes directly to third reading, at a date still to be announced. The Bill includes the following amongst its aims: To require Read more »
What does the election of President Trump mean for compliance?
With some around the world still in a state of shock over the election of President Trump we have had little time to think about what the compliance implications may be. Whilst his acceptance speech was short on policy there could be some compliance ramifications. In the coming days seasoned Trump-watchers are likely to have Read more »
France adopts new Sapin II anti-corruption law
Yesterday Tuesday 8 November the French National Assembly (the lower house of Parliament) adopted a much anticipated bill on the fight against corruption – the Sapin II law. These new rules will allow for something similar to the UK’s “deferred prosecution agreements” to be reached for corporates under the supervision of judicial authorities. Businesses with Read more »
SCCE Chicago 2016 wrap up: podcast interview with Jonathan Armstrong
Tom Fox of FCPA Compliance & Ethics caught up with Cordery lawyer Jonathan Armstrong, Jay Rosen, Mike Volkov and Matt Kelly at the SCCE 2016 Compliance and Ethics Institute conference in Chicago to discuss their presentations and observations. Jonathan Armstrong is a lawyer with Cordery in London where his focus is on compliance issues. Jonathan Armstrong Office: +44 (0)207 Read more »
Failure to prevent bribery – Scottish Court confirms shareholders can be punished
Introduction In April 2016 we talked about the proceedings brought in Scotland by the Crown Office and Procurator Fiscal Service against Braid Group (Holdings) Limited which is a holding company for various subsidiaries in the freight and logistics business. That case was one of the first prosecutions under Section 7 of the UK Bribery Act Read more »
UK Financial Conduct Authority takes action on third party risk
Introduction The UK Financial Conduct Authority (FCA) announced the result of its investigation into the use of third parties in the insurance industry at the end of July which has wider indications as to how regulators see third party risk. This work was set out as one of the FCA’s key priorities in their 2015/16 Read more »
UK Serious Fraud Office Annual Report shows continued modest progress
Introduction David Green CB QC, the Director of the Serious Fraud Office (“the SFO”) recently published his annual report (2015-2016), which can be found here: https://www.sfo.gov.uk/download/annual-report-2015-2016/ The SFO acts as an independent governmental authority tasked with investigating and prosecuting the most serious or complex fraud and domestic and overseas corruption under the UK Bribery Act Read more »
Protection under the law
Cordery’s André Bywater has written an article about complying with the UK’s Modern Slavery Act for Ethisphere’s special report on human rights. You can view the article here. André Bywater is a commercial lawyer with Cordery in London where he focuses on regulatory compliance, processes and investigations. André Bywater, Cordery, Lexis House, 30 Farringdon Read more »
Agreement on EU Conflicts Minerals Rules
General political agreement was recently reached on draft EU legislation concerning conflict minerals, which will impose compliance supply-chain due diligence requirements. We reported on the previous development of this issue in detail over a year ago here. The draft European Commission proposal (now amended by the European Parliament and the EU Council) consists of a Read more »
Recent Developments in Bribery and Corruption
It was something of a good news, bad news week for the Serious Fraud Office last week with the announcement that they have agreed a second deferred prosecution agreement but with the news that the politician who previously sought their abolition is now Prime Minister. Second DPA We looked at the UK’s first deferred prosecution Read more »
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