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Polly Sprenger Discusses Precedent for Turning Over Internal Investigation Notes to the SFO

Firm News | July 3, 2018

Litigation partner Polly Sprenger was quoted by Global Investigations Review regarding precedent set by the Serious Fraud Office (SFO) that could result in companies having to hand over the written notes of internal investigation interviews. Polly noted that the SFO's prior stance on internal investigation notes made it difficult for lawyers advising companies on obtaining Deferred Prosecution Agreements (DPAs). She stated that the code of practice for DPAs needs to be expanded to include information on how exactly the SFO will formally deal with interview notes. "We have one small paragraph in the code [on cooperation] and unless it is extended we are going to see a lot more court time dedicated to these issues." ("GIR Live: SFO to Demand Interview Notes Following XYZ-Related Judgment," June 29, 2018)

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