*Director of the Serious Fraud Office v Eurasian Natural Resources Corporation Ltd

Documents created during criminal investigation not legally privileged – . The Queen's Bench Division substantially granted the claimant Director of the Serious Fraud Office's application for a declaration that documents generated by the defendant company during investigations by its solicitors and forensic accountants into its activities against the background of an ongoing criminal investigation were not subject to legal professional privilege. However, documents indicating or containing the factual evidence presented by a solicitor to the defendant's committee and/or board attracted legal advice privilege.

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