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ARTICLE · 16 DECEMBER 2015

Important New Principles Emerge From UK's First-Ever Deferred Prosecution Agreement And US DOJ Declination

Jones Day
Jones Day
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The UK's first-ever deferred prosecution agreement ("DPA") was concluded on 30 November 2015.

GlobalCriminal Law
Jones Day
Jones Day
Sion Richards
Sion Richards
Hank Walther
Hank Walther
Glyn Powell
Glyn Powell
Samir Kaushik
Samir Kaushik
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The UK's first-ever deferred prosecution agreement ("DPA") was concluded on 30 November 2015. This unprecedented resolution on which Jones Day acted and which also saw the first use of section 7 of the UK Bribery Act—failure to prevent bribery by employees or associated persons—has understandably received widespread media coverage. The reporting to date has focused on the factual background and the novelty of the proceedings, but the matter raises other new and important points which will be relevant to future cases, namely:

  • The resolution of multijurisdictional investigations;
  • Judicial approval of resolutions;
  • How uncharged third parties are referred to in DPA documents; and

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