U.K. Guidelines Emphasize Importance Of Robust Programs

In January, the Sentencing Council of England and Wales issued its first set of guidelines applicable to corporate white collar offenders.¹ The guidelines, which cover fraud, bribery and money laundering offenses committed by companies, will apply to sentences imposed on or after Oct. 1, regardless of the date of the offense. Given the high-profile fraud and bribery investigations currently being conducted by the U.K. Serious Fraud Office, a U.K. court may soon be called on to apply the guidelines in high-profile matters.

The guidelines provide an unambiguous message to companies regarding the importance of corporate compliance programs, particularly anti-corruption and anti-money laundering systems. The guidelines are clear that companies without these programs are more likely to be prosecuted criminally and receive stiffer sentences. Accordingly, corporations subject to the criminal jurisdiction of the U.K. should review the scope and status of their