In the letter, we ask the SFO to look at:
- whether the regime provides sufficient incentives for companies to self-report
- whether senior executives are being held to account effectively
- whether the penalties imposed reflect the full wrongdoing committed
- whether compensation principles are being effectively applied in DPAs
- whether there is enough transparency in the DPA regime and
- whether Article 6 of the OECD Convention is being sufficiently respected particularl with regard to the national economic interest.