LONDON—The U.K. Serious Fraud Office knows it is in a delicate position these days. Still, that’s not to say the SFO is in a weak position, and compliance officers ignore that distinction at their peril.
At least, that’s my impression after a recent interview with one of the agency’s top prosecutors: Ben Morgan, appointed to the SFO last summer as head of its anti-corruption enforcement unit. We talked about a wide range of subjects, from possible guidance from the SFO (don’t exect much of it), to self-disclosure of misconduct (do more of it), to how judges will review deferred-prosecution agreements under the Bribery Act (more unpredictably than judges here). Two things became apparent in our conversation.
