When dealing with litigation in various different jurisdictions, the Getting The Deal Through guides (GTDT) provide guidance, by way of a series of questions and answers. In the case of international government investigations, the GTDT guides offer important legal insight into government investigations in various jurisdictions, including the United States, Japan, Italy, Australia and Hong Kong. In doing so, they address various issues, including the government agencies responsible for enforcement in each jurisdiction, whether a particular jurisdiction recognises a legal concept of corporate criminal liability, which events trigger a government investigation, and the existence of whistleblower protections in each jurisdiction.
The International comparator tool is designed to allow lawyers to compare legal differences across two or more jurisdictions in any given practice area. Using information from the GTDT guides, it can generate answers to your comparison requests. This is a valuable aid to uncover issues in cross-border matters and multi-jurisdictional issues.
The International comparator tool can be accessed here.
For detailed information on the UK laws governing government investigations, see:
Corporate criminal liability—overview
Corporate offences—overview
Corporate criminal investigations—overview
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