Bribery & Corruption
Peters & Peters has acted in many of the best known and most significant bribery and corruption cases over the last 40 years.
Our team regularly advises corporations and individuals around the world under investigation in complex and high-profile international cases.
The UK Bribery Act governs the conduct of companies and individuals in respect of bribery and related corrupt practices such as facilitation payments and improper business or hospitality expenses. It has far-reaching effects and captures misconduct overseas. Those found guilty of corruption face unlimited fines and up to 10 years’ imprisonment for individuals.
We frequently act for corporations and individuals facing criminal investigations and prosecutions, often where multiple agencies are involved. We can help to deal with internal investigations relating to bribery and corruption as well as managing the relationship with enforcement agencies in the UK and overseas.
We have acted for companies and individuals subject to investigations in the UK and beyond. This includes investigations by the UK’s Serious Fraud Office (SFO), National Crime Agency (NCA) and police. We regularly interact with agencies around the world such as the US Department of Justice (DoJ), the US Securities Exchange Commission (SEC) and the Swiss State Secretariat for Economic Affairs (SECO). We can advise on issues relating to self-reporting, deferred prosecution agreement, civil recovery orders and SOCPA agreements.
Our team is well-versed in giving strategic direction and practical advice which often results in cases being discontinued or in not guilty verdicts at trial.
For companies that have been the victims of bribery and corruption, we offer a wide range of services to recover assets, including Commercial Litigation and Asset Tracing & Recovery.
We also offer advice on Corporate Compliance programmes to mitigate the risk of further incidents of bribery and corruption within an organisation.
Our expertise in this field has been widely recognised. We were invited by the UK Parliament to advise on the UK legislation and by the Organisation for Economic Cooperation and Development (OECD) to report on the UK’s performance in taking effective anti-corruption measures. We were also asked to assist the Association of General Counsel and Company Secretaries of the FTSE 100 (GC100) in preparing its submissions to the House of Commons Joint Committee considering the Bribery Bill.
- We were instructed to advise a global group operating in 120 markets in relation to the sufficiency of its anti-bribery and corruption systems and controls, and to draft a bribery and corruption policy for the group in line with international best practice (US FCPA and UK Bribery Act).
- We acted for the Hungarian national oil and gas company, MOL, in a major dispute with Croatia involving domestic criminal liability under both Croatian and Hungarian law, international standards for criminal investigations and prosecutions, mutual legal assistance, extradition, the granting of safe passage, the issuance of Red Notices, and the enforceability of arbitral awards.
- Peters & Peters represented a conglomerate following the execution of multiple search warrants by the SFO. The SFO investigation arose as a result of, and in conjunction with, worldwide enquiries, investigations and prosecutions. The conglomerate, its agents, officers and employees were suspected of making corrupt payments to foreign public officials over a number of years and in a number of jurisdictions.
- We represented a high profile client in the Middle East, linked to the widely reported international investigation into the alleged misappropriation of assets from the Malaysian 1MDB sovereign wealth fund. We acted as primary legal advisor and coordinator of the global defence strategy. We managed an international team of law firms, managing responses to investigations in each jurisdiction and significant reputational issues for the client.
- Peters & Peters represented the former Business Director of a very large international chemicals company. Following an SFO investigation, the company pleaded guilty to bribery in Indonesia and Iran, and was sentenced in the UK and US. Unlike his co-defendants, our client avoided imprisonment and confiscation proceedings as a result of his cooperation.
- We acted for the former financial controller of an international group of companies servicing the oil and gas sectors, in a prosecution brought by the Serious Fraud Office (SFO). The allegations were that four defendants conspired to make corrupt payments to agents of two Nigerian State Boards of Internal Revenue for the purpose of avoiding, deferring or mitigating the tax liabilities of the company for whom the defendants worked. After a nine week trial our client was acquitted.