A blog post on the FCPA Blog on 21 January reported that the UK Serious Fraud Office has published, with very little fanfare, new 8-page guidance about how it assesses the effectiveness of the companies it investigates.  It is said that the guidance is actually part of the SFO’s Operational Handbook, which by its terms is “internal guidance” for the SFO only.  The new guidance pays close attention to the 6 principles detailed in the Bribery Act guidance from the MoJ in 2011.  However, the post says that what the business world needs to know is just how the SFO weighs up precisely what it will consider adequate – but there is little that is new or noteworthy in the guidance that assists in this.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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