Key takeaways:

• Civil recovery proceedings against shareholders to recover dividends deriving wholly or partially from unlawful conduct are firmly on the SFO’s agenda, irrespective of the shareholders’ culpability or knowledge of the underlying conduct.
• The civil recovery order obtained by the SFO is the latest and final instalment in the SFO’s pursuit of Mabey & Johnson, which has seen the company become the first (and still only one) to be criminally convicted for bribery in the UK and several of its former directors and managers also convicted and sentenced.
• The SFO is thus sending out a clear message to the investment community that it bears full responsibility for its investment decisions and that the proceeds of investments may be targeted where corruption issues arise.