If a business has just uncovered a problem as a result of undertaking a risk assessment as part of Bribery Act preparations or there is risk, for example following the Arab Spring, that one is likely to emerge, then now may be the time to deal with this using the SFO’s self reporting procedure. Considering such a step is something which should not be done lightly and certainly not without legal advice. However, from a practical standpoint there is a window of opportunity now to deal with these issues in good faith which will not stay open forever.
‘Enforcement 40’ for 2020
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