It is easy for US lawyers to forget that the attorney-client privilege and work product protection may be applied much more narrowly in other countries, leaving unprotected materials that attorneys here may have assumed would be protected.  A recent reminder of this comes by way of Serious Fraud Office v. Eurasian Natural Resources Corp. LTD, [2017] EWHC 1017 (QB) (May 8, 2017).  The matter arises from a criminal investigation by the Serious Fraud Office (SFO) into corruption allegations involving Eurasian Natural Resources Corporation Ltd. (ENRC).  ENRC engaged outside counsel who interviewed numerous employees and reported to ENRC and its board.  The SFO later applied for a declaration that certain documents created by the lawyers, including memoranda of the employee interviews, were not privileged and were thus subject to disclosure.  Relying on other recent precedents, the High Court generally agreed.  The High Court found that the legal advice privilege (comparable to the attorney-client privilege) did not apply because the interviews were not shown to be of employees who were acting as the client’s agent for purpose of obtaining legal advice.  It found – unlike most jurisdictions in the United States – that the privilege does not apply to interviews conducted solely to apprise the lawyers of the facts as a predicate for the lawyers’ formulation of legal advice.  The High Court further found that the materials were not protected as lawyer working papers because, being simply factual descriptions of the interviews, the memoranda did not reflect the legal advice that was provided.