Noticeboard
Overseas corruption - Self-reporting to the SFO
In the summer the SFO issued a policy document called the “Approach of the Serious Fraud Office to dealing with overseas corruption” (http://www.bcl.com/downloads/sfodealingwithoverseascorruption.pdf). It is aimed at encouraging companies which identify overseas corruption problems to “self-report” these problems to the SFO. The incentive for self-reporting is the prospect of a civil sanction as opposed to criminal prosecution and the SFO will no doubt point to AMEC’s recent civil settlement of £4.95 million (http://www.bcl.com/downloads/SFOobtainsCivilRecoveryOrderagainstAMEC.pdf) as an example of how a company can achieve a more favourable outcome if it self-reports to the SFO, co-operates in the subsequent investigation and demonstrates a commitment to improve its ethics and compliance (in this case through the appointment of an external consultant). Richard Sallybanks, who is currently instructed in a number of SFO corruption investigations, has recently contributed articles to a number of publications on this issue and the text can be accessed via this link www.bcl.com/downloads/Corruptionarticle161009.pdf
