On 14 October, an article from Herbert Smith Freehills reported on a renewed  appeal against a ruling which had determined that the SFO can require a foreign company to produce documents held overseas, pursuant to section 2(3) of the Criminal Justice Act 1987.  The High Court had held that the provisions had extraterritorial application to foreign companies in respect of documents held abroad, where there was “a sufficient connection between the company and the jurisdiction”.  It is said that the Appeal went ahead, notwithstanding that, in August 2020, KBR Group stated that the US DoJ and the SFO were no longer continuing the underlying investigation into it, in respect of alleged corrupt payments to Monaco consultancy Unaoil.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

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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