Is Global Enforcement Parity the New Norm?

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.

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