Menu11/5/19: An article by law firm Skadden, Arps, Slate, Meagher & Flom LLP compares the practices of the UK, France and the US on transatlantic cooperation...
According to the article comparing recently published guidance by the UK and France,” Both sets of demonstrate further alignment of those jurisdictions’ deferred prosecution agreement (DPA) regimes with long-standing practices in the U.S., albeit with some notable areas of divergence.” The article then moves on to examine those areas of divergence including issue of privilege and access to overseas records. It’s an article work reading for companies with familiarity with US practices and interests in the UK and France...
