UK SFO revises Qs & As to reflect OECD recommendations

The United Kingdom’s Serious Fraud Office (SFO) has reviewed its policy on facilitation payments, business expenditure and corporate self-reporting and has revised its Questions and Answers page. The revisions were published because following his appointment, the Director of the SFO decided to review SFO policies and take forward recommendations made by the OECD Working Group on Bribery. The revisions have been published to:

• restate the SFO’s primary role as an investigator and prosecutor of serious and/or complex fraud, including corruption;
• ensure there is consistency with the approach of other prosecuting bodies; and
• take forward certain OECD recommendations.

The SFO’s primary role is to investigate and prosecute. The revised policies make it clear that there will be no presumption in favour of civil settlements in any circumstances.

Our London office has prepared a Client Alert on this subject entitled, Is the Serious Fraud Office getting serious? An update on the UK Bribery Act.