SFO Head Lisa Osofsky on Post-Pandemic Priorities, Brexit, DPAs and the KBR Decision

At a moment when chief compliance officers are being told to “tighten belts” and “cut corners” because of the pandemic’s economic impact, they should actually be making the case for sufficient resources, suggested Lisa Osofsky, Director of the U.K. Serious Fraud Office. “The regulatory and the enforcement community are going to look askance” at efforts to cut compliance costs at a time when compliance has become so much more challenging, she added, speaking at SCCE’s 9th Annual European Compliance & Ethics Institute in March. Osofsky cautioned “the powers that be within the corporates” that “now is not the time to take your eye off the ball.” The SFO’s priorities for 2021 “have not changed,” she continued. We digest her comments there and those made during a speech at the inaugural Corporate Compliance Enforcement Conference held by SCCE in February. See ACR’s three-part series on the SFO’s Cooperation Guidance: “Transparency” (Sep. 18, 2019); “Waiving Privilege” (Oct. 16, 2019); and “Internal Investigation Expectations” (Nov. 13, 2019).

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