Ben Morgan, the co-head of the United Kingdom’s Serious Frauds Office (SFO), recently confirmed for the first time that it is the “new norm” for the SFO to consult directly with United States authorities when calculating the penalties it will impose in foreign bribery cases. As Morgan explained to reporters in February, the goal is to seek to impose penalties in U.K. enforcement actions that achieve “parity” with penalties that would have been imposed in a U.S. enforcement action.
Public officials in the United States and United Kingdom long have celebrated mutual enforcement cooperation on anticorruption laws. Morgan’s statement is newsworthy because it offers a rare glimpse into the contours of such multilateral cooperation, including providing a basis for companies to expect parity between the SFO’s anticorruption corporate penalties and those of the United States. As other countries begin enforcing their own anticorruption laws, it will remain important to monitor such cooperation.
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