麻豆视频

On March 20, 2025, the United Kingdom鈥檚 Serious Fraud Office (SFO), France鈥檚 Parquet National Financier (PNF) and Switzerland鈥檚 Office of the Attorney General (OAG) announced the creation of the International Anti-Corruption Prosecutorial Taskforce (the 鈥淭askforce鈥�).[1]听 The Taskforce aims to leverage the wide-reaching transnational anti-bribery legislation of each participating nation, which allows for the prosecution of criminal conduct occurring overseas if there is a connection to the prosecuting country. 听As described in its founding statement, the Taskforce is intended to strengthen existing ties, increase collaboration, and promote the sharing of insights and expertise.[2] 听Through the Taskforce, the three countries will establish a 鈥淟eaders鈥� Group鈥� to exchange 鈥渋nsight and strategy鈥� and a 鈥淲orking Group鈥� to 鈥渄evis[e] proposals for co-operation on cases.鈥�[3]听 The Taskforce also will invite 鈥渙ther like-minded agencies鈥� to join and share best practices.[4] 听

Jean-Fran莽ois Bohnert, Head of the PNF,听noted that the Taskforce 鈥渨ill definitely strengthen our current cooperation in order to fight more efficiently against bribery and corruption in individual cases.鈥�[5]听 Nick Ephgrave, Director of the SFO,听added that the Taskforce 鈥渨ill make use of every power and partnership available to confront . . . the pernicious threat of international bribery and corruption, wherever it occurs.鈥�[6]听

A Changing International Context

The creation of the Taskforce comes at a time of transition for U.S. foreign enforcement. 听Less than two months ago, U.S. Attorney General Pamela Bondi instructed DOJ鈥檚 Foreign Corrupt Practices Act (鈥淔CPA鈥�) Unit to prioritize foreign bribery investigations and prosecutions with a nexus to cartels and transnational criminal organizations.[7]听 Less than a week later, President Trump issued an Executive Order directing DOJ to pause FCPA enforcement altogether for at least 180 days, empowering the Attorney General to review existing FCPA investigations and enforcement actions, and directing the Attorney General to prepare new FCPA enforcement guidelines consistent with the Administration鈥檚 priorities.[8]听 Though Director Ephgrave stated the Taskforce 鈥渋s in no way a reaction鈥� to the American pause on FCPA enforcement,[9] the timing of the creation of the Taskforce may suggest that European authorities perceive a shift in U.S. enforcement priorities.

The Taskforce鈥檚 creation represents an additional step in the coordination of international anti-corruption enforcement. 听While the Head of the PNF, Jean-Fran莽ois Bohnert, noted at the Taskforce鈥檚 inauguration that, the PNF, SFO and OAG have 鈥渢en years of operational cooperation,鈥�[10] prior collaborations generally reflected one-off prosecutions, often with the U.S. as a key participant. 听For example, in 2018, the U.S. and France, with assistance from British and Swiss anti-corruption authorities, secured a nearly $1 billion resolution from Soci茅t茅 G茅n茅rale for a scheme to bribe Libyan officials.[11] 听Similarly, in 2020, British and French authorities worked closely to investigate and fine Airbus 鈧�3.6 billion for allegations of bribery and corruption.[12]听 Most recently, in 2024, British and French authorities began investigating Thales, a British defense firm, on bribery and corruption charges.[13]听 Despite the success of these collaborative efforts, they generally arose in an ad hoc fashion, were not necessarily the result of a sustained coordination strategy, and regularly involved U.S. authorities. 听Similarly, Joint Investigative Teams (鈥淛ITs鈥�) of law enforcement and judicial authorities鈥攁n increasingly popular feature of EU member states鈥� enforcement actions鈥攁re established only for 鈥渁 specific purpose and for a limited period,鈥�[14] not regular and permanent vehicles for cooperation and coordination.

This dynamic may change with the creation of the Taskforce. 听The stated commitment to a 鈥渞egular exchange of insight and strategy鈥� and the desire to 鈥渄evis[e] proposals for co-operation on cases鈥� suggests a more proactive, deliberate and strategic approach to international anti-corruption efforts.[15]听 A coordinated approach could build on (or replace) previous western and European collaboration efforts in this area, such as JITs, Eurojust coordination meetings and centers,[16] and the OECD Working Group on Bribery鈥檚 biannual informal meeting of law enforcement听 officials.[17]听

Implications for Companies

The creation of the Taskforce should serve as a reminder to international companies that anti-corruption enforcement remains a top priority internationally, despite the FCPA pause. 听Companies with operations, clients or footprints in the U.K., France or Switzerland could be exposed to coordinated investigations by this new Taskforce. 听Potential expansion to include other 鈥渓ike-minded agencies鈥� can also expand the Taskforce鈥檚 jurisdictional reach. 听Therefore, companies should remain vigilant in maintaining and improving their corporate governance and anti-bribery and anti-corruption compliance programs and practices.

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[1] 听听听听听听 Serious Fraud Office, 鈥淯K, France and Switzerland announce new anti-corruption alliance,鈥� GOV.UK, Mar. 20, 2025, ; see also 鈥淎ctualit茅s mensuelles - Parquet national financier,鈥� Ministere de la Justice, Mar. 20, 2025, ; 鈥淯K, France and Switzerland announce new alliance to tackle bribery and corruption threat,鈥� Office of the Attorney General of Switzerland, Mar. 20, 2025, .

[2] 听听听听听听 International Anti-Corruption Prosecutorial Taskforce, 鈥淔ounding Statement,鈥� Mar. 20, 2025, .

[3] 听听听听听听 Id.

[4] 听听听听听听 Id.

[5] 听听听听听听 Serious Fraud Office, 鈥淯K, France and Switzerland announce new anti-corruption alliance.鈥�

[6] 听听听听听听 Id.

[7] 听听听听听听 Loretta Lynch, John Carlin, and Mark Mendelsohn, 鈥淏ondi Memos, FCPA Shift Require Compliance Review, Not Pull-Back,鈥� Bloomberg, Feb. 12, 2025, .

[8] 听听听听听听 Id.; see also 鈥淭rump EO Pauses FCPA Enforcement After DOJ Day-One Directives Announce Significant Shift in Priorities, Including the Reorientation of FCPA, FARA and Money Laundering Enforcement,鈥� Paul, Weiss, Rifkind, Wharton & Garrison, LLP, Feb. 13, 2025, /practices/litigation/anti-corruption-fcpa/publications/trump-executive-order-pauses-fcpa-enforcement-after-doj-day-one-directives-announce-significant-shift-in-priorities?id=56513.

[9] 听听听听听听 Ana de Liz, 鈥淯K, French, Swiss agencies set up new anti-corruption taskforce,鈥� Global Investigation Review, Mar. 20, 2025, .

[10] 听听听听听 Serious Fraud Office, 鈥淯K, France and Switzerland announce new anti-corruption alliance.鈥�

[11] 听听听听听 鈥淪oci茅t茅 G茅n茅rale and Legg Mason to Pay Nearly $650 Million to Resolve DOJ Investigation of Libyan Bribery Scheme,鈥� Paul, Weiss, Rifkind, Wharton & Garrison, LLP, June 7, 2018, /practices/litigation/anti-corruption-fcpa/publications/soci%C3%A9t%C3%A9-g%C3%A9n%C3%A9rale-and-legg-mason-to-pay-nearly-650-million-to-resolve-doj-investigation-of-libyan-bribery-scheme?id=26555#_ftn17.

[12] 听听听听听 Aziz Rahman, 鈥淎irbus, international cooperation and the rise of Deferred Prosecution Agreements,鈥� International Bar Association, .

[13] 听听听听听 Serious Fraud Office, 鈥淪FO announces bribery investigation into defence firm,鈥� GOV.UK, Nov. 21, 2024, .

[14] 听听听听听 Europol, 鈥淛oint Investigation Teams 鈥� JITs,鈥� .

[15] 听听听听听 See International Anti-Corruption Prosecutorial Taskforce, 鈥淔ounding Statement,鈥� at supra note 2.

[16] 听听听听听 Eurojust provides support services to European countries fighting crime, including through hosting coordination meetings in cases of cross-border crime. While non-European Union countries like Switzerland and the United Kingdom may participate by invitation, Eurojust has a larger and different member composition, and broader judicial coordination mandate than the Taskforce. 鈥淲ho we are,鈥� European Union Agency for Criminal Justice Cooperation, .

[17] 听听听听听 Since 1997, the OECD Working Group on Bribery has led global efforts to fight bribery of foreign public officials in international trade and investment under the framework of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.听 It鈥檚 key activities include its peer review and monitoring mechanisms, its Tour de Table case review process, and its sponsorship of biannual meetings of law enforcement officials on the margins of the Working Group鈥檚 quarterly meetings. 听This body is expected to play a continuing, central role, but its size and structure is not well-designed for intense, small group, case-specific law enforcement coordination.听 See 鈥淲orking Group on Bribery,鈥� Organisation for Economic Co-operation and Development, . 听One additional limitation is the potential, longer term absence of the DOJ from the U.S. delegation to the OECD Working Group on Bribery, which is headed by the State Department and also traditionally comprised of DOJ, SEC,听 and Commerce Department officials.听 The DOJ did not attend the Working Group鈥檚 most recent meeting in March 2025. 听Gaspard Le Dem, 鈥淒OJ will be a no-show at OECD anti-bribery meetings,鈥� Global Investigations Review, Mar. 10, 2025, .