The Fraud Board

The Fraud Board

Commentary on current cases, news stories and legal developments in international business crime and regulation

McGuireWoods’ London Government, Regulatory and Criminal Investigations Group

Category Archives: Due diligence

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Compliance programmes, Corruption, Deferred prosecution, Due diligence, Enforcement, FCPA, Gifts & hospitality, Guidance, Public officials, Settlement

Weatherford’s “loose controls and anaemic compliance” leads to $253 million bribery and sanctions penalties

This is a salutary tale for any companies, wherever they are situated in the world, which still think that their illegal activities will never be discovered. Usually it is only a question of time, and the penalties can be huge, as well as the impact on the business in sorting it all out… Continue Reading
Compliance programmes, Corruption, Due diligence, Enforcement, Guidance, Jurisdiction, Senior Executives

Anticorruption compliance is more than adopting a policy

When the prosecutors come knocking on the door with a search warrant, one of the first things they will look for is evidence as to whether the company adhered to and fulfilled the six principles of adequate procedures. If one or more of those six steps is missing, the company may have no defence to a prosecution… Continue Reading
Compliance programmes, Corruption, Due diligence, Enforcement, Senior Executives

UK Financial Services Authority fines Willis Limited, insurance brokers, for failures in its anticorruption compliance programme – some sobering lessons for all companies

So, another large insurance broker has been publicly criticised and fined. According to the FSA, this was avoidable as Willis knew what they had to do in terms of compliance and they knew the risks to their business in relation to bribery and corruption, but it appears that their compliance was inadequate in several different respects… Continue Reading
Associated persons, Compliance programmes, Due diligence, Gifts & hospitality, Guidance

BRIEFING NOTE – UK Bribery Act, Section 9 Guidance

The Government has released Guidance on the Act, which is intended to help organisations understand how the Act will operate and how to deal with the risks of bribery. The Guidance gives insights into how the Act might be interpreted, but does not give assurances. It suggests procedures that might be adequate, but does not set down rules… Continue Reading