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Entain DPA: UK enforcement landscape, CPS momentum and due diligence for gambling, acquisitions and third‑party risk

Published on: 25 January 2024

Published by a Law360 reporter
Legal News
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Article summary

Second only in size in the UK to the 2020 global Airbus SE corruption settlement, Entain has acknowledged the corporate offence of failing to prevent bribery as part of a deferred prosecution agreement (DPA). It accepts the alleged shortcomings arising from previous GVC Holdings management missteps. Under the DPA announced on 5 December 2023, the package includes Entain’s agreement to cover HMRC and CPS investigation costs of £10m and to make a £20m charitable payment. Entain is also required to cooperate fully and in good faith with the CPS on any and all matters linked to the conduct at the centre of the underlying allegations, and to take all reasonable steps to implement revisions to its ethics and compliance programme where required. This article outlines the UK’s DPA framework and sets out practical learning points for companies facing third-party risk, with a particular focus on those operating in the betting and gaming sector.

Significance of the DPA

A DPA is a discretionary mechanism available in the UK to the Serious Fraud Office (SFO) and the CPS to resolve corporate criminal cases without a formal admission of liability...

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