June 2014

The recent case of US v Esquinazi has been heralded as something of a game changer in clarifying the extensive nature of “government instrumentalities” under the FCPA. Meanwhile, the UK government has pledged to step up its fight against organised crime and signalled that a review of corporate criminal liability may be on the cards.

We report on the convictions of a number of high profile individuals, in both the UK and the US, for fraud and bribery offences. Recently published guidance from Transparency International on tackling requests for facilitation payments will be welcomed although, as the FIFA allegations demonstrate, all the guidance in the world may not be enough to prevent corruption if the stakes are high enough.

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