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Eleanor Wallis

Eleanor is a Senior Associate in the Dispute Resolution team based in London. Eleanor is a member of the Compliance and Investigations practice group. Eleanor's practice includes a broad spectrum of disputes and investigations, including anti-bribery and corruption investigations, compliance matters and international arbitration.

The Economic Crime and Corporate Transparency Act 2023 received Royal Assent on 26 October 2023. The Act is a landmark development in the UK Government’s long-standing efforts to enhance the UK’s economic crime enforcement framework, and the Act introduces a number of important measures designed to improve corporate transparency and tackle economic crime in the UK
and abroad.

In June 2022, Glencore, one of the world’s largest commodity traders, pleaded guilty to paying bribes to officials in three West African countries and for failing to prevent agents and employees from doing so in two other African countries. On 3 November 2022, Glencore was sentenced and ordered to pay a record amount of GBP 281 million (consisting of a GBP 182.9 million fine, a GBP 93.5 million confiscation order and GBP 4.5 million in respect of the Serious Fraud Office’s costs).

The last 10 to 15 years has seen a significant increase in criminal enforcement against companies, and an increase in co-operation between states when investigating and prosecuting corporate crime. As a result, multi-jurisdictional companies (and their employees) are at greater risk than ever of becoming involved in a criminal investigation, whether as a suspect or a witness. It is therefore important that companies and their employees are aware of the process that will be followed if they are required to provide evidence as part of a criminal investigation, and how best to prepare for that process.