17 Pages Posted: 5 Oct 2010
Date Written: October 4, 2010
The United Kingdom Serious Fraud Office (SFO) is the lead agency in the U.K. for investigating and prosecuting cases of overseas corruption, including cases under the Bribery Act (expected implementation in April 2011).
In July 2010, I received an invitation from Richard Alderman, Director of the SFO, to submit questions to him on any topic of my choosing. I submitted approximately thirty detailed questions covering a broad range of topics, including the role and policies of the SFO, the Bribery Act, the BAE and Innospec cases, Bribery Inc., and other questions of general interest. Except for certain questions regarding the BAE case, which is still pending in the U.K. courts, Mr. Alderman provided answers to every question, including on topics I have been critical of the SFO in the past.
In his answers, Mr. Alderman: (i) compares and contrasts the SFO's role with the DOJ's role in enforcing the Foreign Corrupt Practices Act, including the more active and independent role U.K. courts have in reviewing SFO charging decisions; (ii) talks about voluntary disclosure, and the role of non-prosecution and deferred prosecution agreements; (iii) discusses reputational harm, debarment, and reparations; and (iv) talks specifically about the Bribery Act.
Keywords: Foreign Corrupt Practices Act, FCPA, Bribery Act, United Kingdom, Serious Fraud Office
Suggested Citation: Suggested Citation
Koehler, Mike, A Conversation with Richard Alderman - Director of the United Kingdom Serious Fraud Office (October 4, 2010). Available at SSRN: https://ssrn.com/abstract=1687299 or http://dx.doi.org/10.2139/ssrn.1687299
By Mike Koehler
By Eric Engle
By Mike Koehler