On 5 November, an article from Clyde & Co was concerned with the 9th DPA agreed by the SFO, this time with Airline Services Ltd for a section 7 offence of failing  to implement adequate procedures to prevent one of its agents abusing the tender process, by using commercially sensitive information, to corruptly win contracts for ASL to refit commercial airliners.  The company was allowed more than the normal maximum discount on the financial penalty involved (50% instead of 30%), the presiding judge saying that 50% could be appropriate not least to encourage others how to conduct themselves when confronting criminality.  It also reported on SFO’s revised guidance, issued in October, which raises a number of further important issues, re-emphasising parts of the previous Handbook and enhancing existing factors, reflecting the SFO experience in negotiating DPA.

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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