Bill Waite | Contributing Editor
Bill Waite is a contributing editor of the FCPA Blog.
He’s one of the founders of The Risk Advisory Group, established in 1997 with the objective of building Europe’s leading independent risk management consultancy. He serves as the group’s CEO and general counsel.
He formerly practiced as a criminal barrister before joining the U.K. Serious Fraud Office in 1991 as a prosecutor.
Bill sits on the editorial board of a number of academic periodicals and writes on the FCPA, the Bribery Act, crisis management, and fraud investigations. He edited and contributed to the book Managing Risk and Resolving Crisis, published by the Financial Times. He’s a regular speaker in Europe and the United States and often appears as an expert commentator on the BBC, CNBC, and various radio programs.
He’s a member of the Bar of England and Wales and holds an LLM and LLB.
My first car was a VW beetle. It met its emission standards everywhere it went — which was not far because it did not have an engine.
We are perhaps six weeks away from a deal which would open up a country shunned for nearly four decades.
The Bribery Act 2010 and Department of Justice guidance require businesses to have anti-bribery controls which reflect the risk they face in conducting business.
On June 30, the Justice Department and other federal and state agencies announced the long awaited settlement in the BNP case. The bank forfeited $8.8 billion and paid fines of $140 million for the “hat-trick of sanctions violations” — unlawfully offering the U.S. financial markets to three sanctioned countries: Sudan, Iran and Cuba.
It’s not just the language that divides us. On June 4 the United States Court of Appeals for the Second Circuit handed down its judgment in SEC v. Citigroup Global Markets, Inc. This was not, as the citation suggests, a titanic battle fought to legal death but rather the parties coming together to challenge a federal judge’s decision not to endorse a settlement between them. The SEC and Citigroup were at one in their submissions to the appellate court.
Two years after the Bribery Act 2010 came into force, the hysteria surrounding the Act has abated. There are fewer media pundits pronouncing the end of UK plc as we know it and there are fewer newly invented “legal experts” opining on an area they knew little or nothing about but which they saw as a potential earner to fill the gaping hole left by declining litigation and commercial transactions.
Many, including myself, have expressed doubts about how effective deferred prosecution agreements would actually be.