by Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno, Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, Christopher Cestaro, and Lindsey Cullen
High left to proper: Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno and Kimberly A. Parker. Backside left to proper: Jay Holtmeier, Erin G.H. Sloane, Christopher Cestaro and Lindsey Cullen (Images courtesy of WilmerHale).
Anti-bribery and corruption companies within the UK, France and Switzerland not too long ago introduced a shared dedication to tackling worldwide bribery and corruption, by the use of a brand new taskforce supposed to strengthen collaboration.
This taskforce was introduced by the UK’s Severe Fraud Workplace (SFO), France’s Parquet Nationwide Financier (PNF) and the Workplace of the Lawyer Common of Switzerland (OAG) at a gathering in London. Its founding assertion notes “the numerous risk of bribery and corruption” and states that its members recognise that “success depends on us working carefully and successfully collectively”. It intends to ship a working group for case cooperation and elevated greatest apply sharing.
The SFO, PNF, and OAG have lengthy been lively anti-corruption enforcement companies in Europe and have a observe document of working carefully and nicely collectively. Excessive-profile bribery settlements with firms on which they’ve collaborated embody Rolls Royce in 2017 and Airbus in 2020. A joint investigation into the Thales Group by the SFO and PNF was introduced in November 2024.
Nick Ephgrave, the Director of the SFO, mentioned that this dedication “reaffirms our particular person and collective dedication to tackling the pernicious risk of worldwide bribery and corruption, wherever it happens.” His feedback have been echoed by Jean-François Bohnert, Head of the Parquet Nationwide Financier, who mentioned that the taskforce will “strengthen our present cooperation with the intention to combat extra effectively in opposition to bribery and corruption in particular person instances.”
The importance of this new alliance lies extra in its symbolism and its timing slightly than its sensible impact. The taskforce announcement is mild on sensible element however loudest about what it doesn’t say, specifically that it goals to positively distinguish the UK, France, and Switzerland’s anti-corruption enforcement posture from that of america’s present place on the Overseas Corrupt Practices Act (“FCPA”).
This announcement comes only a month and a half after President Trump issued an Government Order directing Lawyer Common Bondi to conduct a six-month assessment of the rules and insurance policies governing FCPA investigations and enforcement actions, successfully pausing FCPA enforcement. The order got here a couple of days after a memo from Lawyer Common Pamela Bondi instructing america Division of Justice (DOJ) to redirect its enforcement efforts away from company crimes like FCPA violations and towards the Administration’s priorities: combating unlawful immigration, drug cartels, and allegedly illegal DEI practices. Whereas SFO director Nick Ephgrave has indicated that this new alliance and process drive “is on no account a response to that,”[1] we are able to anticipate that it could assist fill the enforcement void created by the FCPA pause in america.
The creation of the taskforce follows efforts in recent times by European companies to develop extra nimble enforcement instruments comparable to deferred prosecution agreements, lengthy accessible in america and the UK, extra not too long ago launched in France, and builds upon rising collaboration amongst these companies over the previous couple of years. The alliance additional highlights the rising function of European regulators in main multi-jurisdictional bribery instances, probably decreasing the DOJ’s historic dominance in such investigations. Certainly, it’s doable that enforcement companies in different international locations will be part of the taskforce sooner or later.
Essentially, the announcement presents a well timed reminder to all these firms who conduct enterprise in Europe that the investigation and enforcement of worldwide bribery and corruption issues stays a legislation enforcement precedence. Anti-bribery laws within the UK, France, and Switzerland has wide-reaching jurisdiction and permits these companies to prosecute felony conduct that happens abroad, if the conduct has a hyperlink to the prosecuting nation, reinforcing the necessity for firms working globally to have efficient compliance applications and anti-bribery measures in place.
[1] https://globalinvestigationsreview.com/article/uk-french-swiss-white-collar-agencies-set- new-anti-corruption-task-force
Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno, Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro are Companions and Lindsey Cullen is a Senior Affiliate at Wilmer Cutler Pickering Hale and Dorr LLP. This publish first appeared as a consumer alert on the agency’s weblog.
The views, opinions and positions expressed inside all posts are these of the writer(s) alone and don’t characterize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College Faculty of Regulation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this website and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the writer(s) and any legal responsibility on the subject of infringement of mental property rights stays with the writer(s).
by Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno, Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, Christopher Cestaro, and Lindsey Cullen
High left to proper: Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno and Kimberly A. Parker. Backside left to proper: Jay Holtmeier, Erin G.H. Sloane, Christopher Cestaro and Lindsey Cullen (Images courtesy of WilmerHale).
Anti-bribery and corruption companies within the UK, France and Switzerland not too long ago introduced a shared dedication to tackling worldwide bribery and corruption, by the use of a brand new taskforce supposed to strengthen collaboration.
This taskforce was introduced by the UK’s Severe Fraud Workplace (SFO), France’s Parquet Nationwide Financier (PNF) and the Workplace of the Lawyer Common of Switzerland (OAG) at a gathering in London. Its founding assertion notes “the numerous risk of bribery and corruption” and states that its members recognise that “success depends on us working carefully and successfully collectively”. It intends to ship a working group for case cooperation and elevated greatest apply sharing.
The SFO, PNF, and OAG have lengthy been lively anti-corruption enforcement companies in Europe and have a observe document of working carefully and nicely collectively. Excessive-profile bribery settlements with firms on which they’ve collaborated embody Rolls Royce in 2017 and Airbus in 2020. A joint investigation into the Thales Group by the SFO and PNF was introduced in November 2024.
Nick Ephgrave, the Director of the SFO, mentioned that this dedication “reaffirms our particular person and collective dedication to tackling the pernicious risk of worldwide bribery and corruption, wherever it happens.” His feedback have been echoed by Jean-François Bohnert, Head of the Parquet Nationwide Financier, who mentioned that the taskforce will “strengthen our present cooperation with the intention to combat extra effectively in opposition to bribery and corruption in particular person instances.”
The importance of this new alliance lies extra in its symbolism and its timing slightly than its sensible impact. The taskforce announcement is mild on sensible element however loudest about what it doesn’t say, specifically that it goals to positively distinguish the UK, France, and Switzerland’s anti-corruption enforcement posture from that of america’s present place on the Overseas Corrupt Practices Act (“FCPA”).
This announcement comes only a month and a half after President Trump issued an Government Order directing Lawyer Common Bondi to conduct a six-month assessment of the rules and insurance policies governing FCPA investigations and enforcement actions, successfully pausing FCPA enforcement. The order got here a couple of days after a memo from Lawyer Common Pamela Bondi instructing america Division of Justice (DOJ) to redirect its enforcement efforts away from company crimes like FCPA violations and towards the Administration’s priorities: combating unlawful immigration, drug cartels, and allegedly illegal DEI practices. Whereas SFO director Nick Ephgrave has indicated that this new alliance and process drive “is on no account a response to that,”[1] we are able to anticipate that it could assist fill the enforcement void created by the FCPA pause in america.
The creation of the taskforce follows efforts in recent times by European companies to develop extra nimble enforcement instruments comparable to deferred prosecution agreements, lengthy accessible in america and the UK, extra not too long ago launched in France, and builds upon rising collaboration amongst these companies over the previous couple of years. The alliance additional highlights the rising function of European regulators in main multi-jurisdictional bribery instances, probably decreasing the DOJ’s historic dominance in such investigations. Certainly, it’s doable that enforcement companies in different international locations will be part of the taskforce sooner or later.
Essentially, the announcement presents a well timed reminder to all these firms who conduct enterprise in Europe that the investigation and enforcement of worldwide bribery and corruption issues stays a legislation enforcement precedence. Anti-bribery laws within the UK, France, and Switzerland has wide-reaching jurisdiction and permits these companies to prosecute felony conduct that happens abroad, if the conduct has a hyperlink to the prosecuting nation, reinforcing the necessity for firms working globally to have efficient compliance applications and anti-bribery measures in place.
[1] https://globalinvestigationsreview.com/article/uk-french-swiss-white-collar-agencies-set- new-anti-corruption-task-force
Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno, Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, and Christopher Cestaro are Companions and Lindsey Cullen is a Senior Affiliate at Wilmer Cutler Pickering Hale and Dorr LLP. This publish first appeared as a consumer alert on the agency’s weblog.
The views, opinions and positions expressed inside all posts are these of the writer(s) alone and don’t characterize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College Faculty of Regulation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this website and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the writer(s) and any legal responsibility on the subject of infringement of mental property rights stays with the writer(s).
