Regulators in Britain, much like their Canadian counterparts, are considered much less aggressive than American regulators when it comes to sentencing for crimes such as insider trading, bribery and white-collar fraud.
To this day, the U.K.’s sentencing regime is considered light in comparison, with the U.S. readily imprisoning countless chief executives in the early 2000’s, as well as securing billions of dollars in penalties from banks, mutual fund companies and insurers. Until recently, the U.K.’s Financial Services Authority (FSA) rarely sought fines above £1m, and failed to bring about a single criminal insider dealing case until 2008.
In light of three new cases, involving David Einhorn of Greenlight Capital, Ravi Sinha of the U.S. private equity firm JC Flowers and one involving three former Credit Suisse bankers charged with fraud, the glaring differences between the enforcement of U.S. and U.K. laws has come under scrutiny.
As a result, the U.K. is stepping up. Regulators are adopting some of the most aggressive U.S. tactics and recently, the U.K. enacted a ban on bribery that that rivals the severity of bans in the U.S. Edward Garnier, the solicitor general, has also proposed the introduction of deferred prosecution agreements akin to those across the Atlantic.
Read more about the plans of UK regulators, and how they hope to become more powerful than Wall Street expects.