An article from Mishcon de Reya on 21 July considers the recent DPA involving a subsidiary of G4S and the SFO. In addition to a financial penalty of £38.5 million and the SFO’s costs of £5.9 million, the DPA includes a provision that the SFO will select an independent external reviewer (or monitor) who will report and recommend an implementation plan to the SFO by the end of 2020. The monitor will then continue to review, assess and recommend improvements to the compliance programme throughout the duration of the DPA. It will also report on steps taken to implement recommendations and improve the company’s compliance programme. The article says that appointment of a US-style independent compliance monitor to oversee the implementation of a corporate’s programme of remediation is more onerous and far reaching than the provision, seen in most previous DPA.
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