SFO's Cooperation Guidance Feels Like A Missed Opportunity

Law360 (September 27, 2019, 2:04 PM EDT) -- So, finally, we have the Serious Fraud Office’s Corporate Cooperation Guidance. SFO Director Lisa Osofsky has made it clear she is a firm advocate of cooperation, so this guidance was always going to be significant.

The guidance has arrived in the form of a five-page document. In it, the SFO defines cooperation as "providing assistance to the SFO that goes above and beyond what the law requires" and details 11 general practices that companies should consider when preserving material and giving it to the SFO. But while welcome, the five pages seem to offer little in the way of genuinely valuable...

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