The Financial Conduct Authority and the Prudential Regulation Authority (together, the “Regulators”) have jointly fined Barclays’ CEO, Jes Staley, a total of £642,430. The fine was imposed for Mr Staley’s repeated attempts to uncover the identity of an anonymous whistleblower, which constituted a failure to act with the due skill, care and diligence the Regulators expect from a CEO. The case was observed with interest as the first brought by financial regulators under the UK’s Senior Managers Regime. The Regulators chose not to impose more severe sanctions (which could have involved the removal of Mr Staley from his role) after failing to find that Mr Staley was guilty of any deliberate wrongdoing. Continue Reading UK Regulators Fine Barclays’ CEO for Errors of Judgement in Relation to Whistleblower
Sunil Gadhia’s practice focuses on English and international disputes, investigatory and enforcement work.
2017 was a year of transition and change in the world of cross-border investigations. In the U.S., the first year of the Trump administration brought questions about enforcement priorities and approach. In the U.K., the debate continued over whether lawyers’ work in furtherance of internal investigations enjoys privilege protection. Globally, new enforcement authorities stepped forward, while companies worked to incorporate new guidance and enforcement priorities into their corporate compliance programs.
Looking back, we focus on five key themes from 2017:
a) corporate resolutions;
b) developments in legal privilege;
c) corporate responsibility;
d) cross-border inter-agency cooperation; and
e) cross-border data transfers.
We also look to the future to address what we consider to be some of the key characteristics of the current cross-border investigations landscape that may influence significant developments in this field in 2018.
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