The UK Serious Fraud Office (SFO) announced earlier this week that it had obtained a civil recovery order from the High Court requiring Oxford Publishing Limited (OPL), a whollyowned subsidiary of Oxford University Press (OUP), to pay £1,895,435, plus prosecution costs. This amount represents profits OPL is thought to have generated through the unlawful conduct of its Kenyan and Tanzanian subsidiaries. This is the latest in a series of civil recovery orders agreed to by the SFO and granted under Part V of the UK Proceeds of Crime Act 2002 (POCA). It provides companies with further guidance on some of the factors that the SFO will consider when deciding whether to pursue a criminal prosecution or a civil remedy in the context of a voluntary disclosure.
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