
Prosecutors and regulators across the globe are becoming increasingly active in enforcing anti-corruption legislation. The number of enforcement actions, the number of jurisdictions within which enforcement actions have been brought and the size and nature of fines and penalties have all increased significantly over the last few years.
In the UK, a major construction company was fined £2.25 million by the Serious Fraud Office as a result of accounting irregularities in connection with a project in Egypt. In another recent case, the Financial Services Authority imposed an unprecedented £5.25 million fine on a leading global insurance broker for failing to establish and maintain effective anti-corruption systems and controls.
The largest penalty levied by the US was, as widely reported, the US$800 million that Siemens agreed to pay to settle actions with the Department of Justice and Securities and Exchange Commission.
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