Deferred Prosecution Agreement For UK Business Includes Required ‘Corporate Renewal’ And Reviewers

Highlights
A deferred prosecution agreement (DPA) with the United Kingdom’s Serious Fraud Office yields the first appointment of an external "reviewer," which appears to be a role similar to that of "monitors" under such U.S. Department of Justice agreements
The DPA’s required "corporate renewal program" entails examination, analysis, review, and audits of rehabilitation efforts
The parent company guaranteed oversight of this "corporate renewal program" at the wholly-owned subsidiary and has already undertaken remediation steps itself
In early July, G4S Care and Justice Services (UK), Ltd (G4S) entered into a deferred prosecution agreement with the United Kingdom’s Serious Fraud Office (SFO). That three-year deferred prosecution agreement (DPA) received judicial approval then on July 17, 2020.
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