Bribery Act & Proceeds of Crime - Written by on Tuesday, August 20, 2013 0:28 - 0 Comments

New Joint Head of Bribery & Corruption Appointed at the SFO

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In a press release issued yesterday the SFO and David Green confirmed a new Joint Head of Corruption at the SFO (replacing Patrick Rappo who recently left to join Steptoe & Johnson).  The SFO statement says:

New SFO Joint Head of Bribery and Corruption

19 August 2013

Today, Ben Morgan commences his appointment as Joint Head of Bribery and Corruption at the SFO.

At the start of his new role Ben Morgan said “During my recent secondment here I saw first hand the excellent work that the Director, his management team and the SFO staff are doing. I am delighted that an opportunity has arisen to be a permanent part of the organisation and look forward to contributing to the important work the office does”.

Ben will be providing strategic direction and operational expertise to a number of complex fraud and corruption cases as well as leading and guiding case managers and their teams. The appointment is a permanent position.

The Director of the SFO, David Green CB QC said:

“I am delighted to welcome Ben Morgan to the SFO’s senior management team. That someone of his calibre and professional background chooses to work at the SFO speaks for itself.”

Ben was seconded to the Fraud division of the SFO in July 2012 and joins us from Norton Rose Fulbright where he was a senior associate in the Business Ethics and Anti-Corruption team, dealing with major multi-jurisdictional investigations and compliance matters.  He worked with businesses across a range of industries including financial institutions, oil and gas, mining, logistics and transport.

Prior to this he was a commercial litigator at the London office of US firm K&L Gates LLP.


It is no exaggeration to say while the SFO Director has rightly highlighted the significant focus the SFO has on the LIBOR investigation there remains significant global interest in the investigation and prosecution of international bribery offences under the UK Bribery Act.

The new Co-Head of Bribery and Corruption arrives at a critical time.  Last week the SFO charged its first Bribery Act offences. This is to be welcomed.

It should not be forgotten that the Bribery Act came on the statute books with massive hype about the impact to UK corporates and their risk of prosecution.

Two years on and the threats of investigation and prosecution (or otherwise disposing of) a corporate investigated for bribery (and relevant individuals) under the Bribery Act are seen by some as hollow.  We do not subscribe to this view – and we advocate strongly that corporates should not be complacent.

That said, it is is no exaggeration to say that the world is watching.

We wish the new Co Head of Bribery and Corruption good luck!

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