A tough new SFO policy means companies need lawyers on their
side and rigorous adequate procedures in place.
The Serious Fraud Office (SFO) have recently published a new
policy relating to gifts and hospitality, facilitation payments and
self-reporting under the Anti-Bribery Act 2010, withdrawing all
previous SFO guidance in the process. This policy marks the arrival
of the new director of the SFO, David Green CB QC and a tougher
approach to enforcement. It is also slams the door firmly shut on
the previous director, Richard Alderman's "come and
talk" invitation to companies. It is what is being termed as a
return to basics with David Green reminding companies that "we
are investigators and prosecutors. We are not here to offer advice,
to preach or to make moral judgments".
