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Navigating cooperation demands of SFO and DOJ in cross-border internal investigations

Dechert LLP


As firms develop new markets and business models around the world, it is important that they maintain adequate controls to mitigate their exposure to the risk of prosecution by the Serious Fraud Office (SFO) or the US Department of Justice (DOJ).  In particular, it is essential for all senior management and legal and compliance personnel to understand the cooperation expectations of both the DOJ and the SFO before a firm conducts its own internal investigation, as a failure to understand this guidance may jeopardise a firm’s ability to qualify for a deferred prosecution agreement in future.

On 6 August 2019 the SFO – the prosecuting authority responsible for tackling serious or complex fraud and bribery in the United Kingdom – published updated Guidance on Corporate Cooperation.  Over the past five years, the DOJ has also repeatedly revised various aspects of its corporate cooperation guidance, as reflected in its Principles of Federal Prosecution of Business Organisations.

This webinar will discuss the SFO’s recent Guidance on Corporate Cooperation and compare it with the principles articulated by the DOJ, highlighting the key areas for firms to consider when assessing whether and how to cooperate.

The webinar will cover:

  • the expectations on firms, including:
    • what cooperation is and why it matters;
    • when firms should consider cooperation;
    • how firms are expected to cooperate with the SFO (including an overview of the SFO Guidance on Corporate Cooperation, how to make internal investigations SFO compliant and whether firms can cooperate and maintain legal privilege); and
    • the key differences in cooperation with the DOJ; and
  • parallel investigations – namely:
    • the keys to navigating the demands of both the SFO and the DOJ simultaneously; and
    • what firms can do to proactively prepare for a multijurisdictional investigation.


Matthew Banham, Partner

Matthew Banham is an established practitioner who specialises in financial crime and regulatory enforcement investigations. His rare combination of experience gained from working in-house in the financial service industry, as well as working for the FCA and the SFO ensures clients receive sound strategic advice when navigating the multi-agency landscape.

Mr Banham advises firms and individuals on complex global investigations and advises on money laundering regulations and anti-corruption compliance. He focuses his practice on multi-agency and cross-border investigations with an emphasis on international investigations.

Mr. Banham is noted by Legal 500 as a lawyer who "absorbs huge quantities of information with a remarkable facility" and "commands the respect of the court and his peers."

Prior to joining Dechert, Mr. Banham served as the senior vice president of Barclays Bank's litigation investigations and enforcement division where he advised and managed external investigations and regulatory risks for the investment bank.

Matthew Mazur, Partner

Matt Mazur is an experienced American litigator who advises corporate and individual clients in U.S. government investigations and enforcement proceedings, internal investigations, and related litigation.  Based in London, Mr. Mazur has significant experience in multi-agency and cross-border investigations involving a range of U.S. authorities, including the DOJ, the SEC and the CFTC.  He also litigates complex commercial disputes in U.S. federal and state courts, as well as commercial arbitrations.

Mr. Mazur has been lead defense counsel or co-counsel in over twenty jury trials and bench trials, and he has briefed and argued over twenty appeals before the New York Court of Appeals, the Appellate Division of the New York Supreme Court, and the United States Court of Appeals for the Second Circuit.  Before joining Dechert in 2011, Mr. Mazur served for seven years as a public defender at the Public Defender Service for the District of Columbia and also the Office of the Appellate Defender in New York City. 


Matthew L. Mazur
Matthew Banham


9 January 2020
16:00 - 16:55 UTC
55 min