Despite regular criticism over the past several years from commentators in both the U.K. and the U.S. with respect to its core competency and commitment to adequate resourcing of its enforcement efforts, the U.K.’s white-collar prosecuting agency, the Serious Fraud Office (“SFO”), is showing signs of having turned a key enforcement corner. In this client alert, we survey the relevant criticism of the agency, provide an update on enforcement of the U.K. Bribery Act — including the outlook for 2013 — and underscore the implications of changes at the SFO for multinational corporate compliance programs.
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