Financial crime: the UK’s first Deferred Prosecution Agreement

On 30 November 2015, Lord Justice Leveson approved the UK’s first Deferred Prosecution Agreement (DPA) between the Serious Fraud Office and ICBC Standard Bank plc (Standard Bank), sparing the bank from being prosecuted under section 7 of the Bribery Act 2010 for one count of failing to prevent bribery by employees or associated persons so long as it meets financial orders to the tune of over US$25 million and, over the next three years, implements a comprehensive corporate compliance programme.

In Jonathan Fisher QC’s 'Quarterly Commentary', first published in the Lloyds Law Reports: Financial Crime, Part 1 of 2016, he sets out why the UK’s first deferred prosecution agreement, praised as a milestone in the policing of corporate offending in the UK, is particularly significant.

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