On 29 October 2015, Ben Morgan, Joint Head of Bribery and Corruption at the Serious Fraud Office (SFO), delivered a speech at the Annual Anti-Bribery & Corruption Forum in which he discussed how companies should engage with the SFO.
Mr Morgan explained that it is in companies’ interests to self-report to the SFO, to do so at an early stage, and to cooperate fully. He also identified points that the SFO would want to discuss with companies that seek advice on how to frame their internal investigations, including:
- identification of relevant witnesses and agreeing the sequence of interviews; and
- . the extent to which companies would disclose the factual elements of interviews already conducted, and to which claims of privilege would be asserted.
Finally, he stated that, companies should aim to handle and present data in a manner that simplifies the SFO’s work.