Bribery & Corruption

"She's formidable. If I was in trouble I would want her in my corner; she really goes to town for her clients." — Chambers 2024

Our team advises individuals and companies in relation to allegations of bribery, compliance and internal investigations.

Bribery legislation has a wide scope. Individuals and companies can be investigated or prosecuted for misconduct occurring in the UK and overseas, relating to corrupt practices, facilitation payments, improper gift and hospitality expenses as well as failure to prevent.

Multinationals, household names and firms in the regulated sector are under greater scrutiny and are likely to be obligated to investigate or report allegations or suspicion of bribery.

This means boards and their senior executives have to be seen to respond appropriately or may be subject to allegations of wrongdoing themselves.

We help whether you are a suspect, witness, whistle-blower or investigator and typically advise how to deal with internal investigations, managing the relationship with law enforcement agencies as well as acting in relation to investigations brought by the Serious Fraud Office (SFO), Her Majesty’s Revenue and Customs (HMRC), National Crime Agency (NCA) or police.

We advise on internal investigations, self-reporting and seeking immunity, defending prosecutions, corporate due diligence on M&A transactions, internal compliance, adequate procedures, policies and training.

We are very experienced and knowledgeable in advising on and representing clients at internal, compulsory or ‘under caution’ interviews.

We know and work closely with other UK law firms and assist and support clients with the corporate due diligence required on M&A transactional work. We also co-counsel with overseas lawyers where there is exposure or risk in other jurisdictions.

Our Experience

Acted for senior executives subject to compulsory information requests, interview under compulsion or interview under caution in the SFO investigations of British American Tobacco, GlaxoSmithKline, Rolls Royce and Unaoil.
Advised airline conducting M&A corporate due diligence on acquisition company where disclosure was made of overseas bribery risks leading to further investigation.
Advised financial institution in relation to aviation company self-reporting alleged bribery offences to the SFO (which ultimately culminated in a Deferred Prosecution Agreement).
Advised FCA authorised firm how to respond to whistle-blowing report of corruption within a finance team, scoped the structure and plan for an internal investigation.
Acted for UAE based international distributor subject to internal investigation and compliance review relating to facilitation payments and bribes in CIS region by US listed security equipment manufacturer.
Acted for businessman supplying goods to IKEA prosecuted by the SFO for paying bribes to two of IKEA’s executives.
Acted for News International journalist under investigation in ‘Operation Elveden’, the police investigation into allegations of inappropriate payments to police and public officials. Client was cleared.
Advised a former General Counsel of a major multinational company in major SFO overseas corruption investigation.
Successfully defended an individual at trial prosecuted by the SFO, who was unanimously acquitted of three counts of corruptly agreeing to make payments.
Advised the CEO of a Greek shipping company (with UK subsidiaries) as to potential criminal offences committed under the Bribery Act 2010.

Funding

We discuss the funding options, the proposed scope of work and budget with you. Depending on the situation, you should check whether you have any legal expenses insurance (for example under professional indemnity, Directors’ & Officers’ or household insurance policies) or consider whether a third party, such as an employer, will contribute to your legal fees (eg under an indemnity).