Client Alert

| January 19, 2012

Mabey & Johnson - "The Final Act": Unprecedented Action by SFO Recovers Shareholder Dividends from Unlawful Transactions

On January 13, 2012, the UK Serious Fraud Office (SFO) announced a High Court Order providing for the recovery of a shareholder dividend paid by Mabey & Johnson Ltd (Mabey & Johnson) derived from contracts won through unlawful conduct (see SFO Press Release). Mabey & Johnson, a privately-owned engineering company, was convicted of sanctions offences relating to Iraq bridge-building contracts in September 2009. The High Court proceedings, which concluded all matters related to a SFO self-referral by Mabey & Johnson in 2008, have been described by Richard Alderman, Director of the SFO, as: "the final act in an exemplary model of corporate self-reporting and co-operative resolution."

This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent. For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383