The U.K. Supreme Court has handed down its much-anticipated judgment in the KBR case, unanimously ruling in February 2021 that the SFO’s powers under Section 2(3) of the Criminal Justice Act 1987 do not extend to compelling a foreign company located wholly outside of the U.K. to produce documents in the U.K. In this guest article, Cooley attorneys Tom Epps and Marie Kavanagh analyze the case and discuss the practical implications on overseas document production. See our three-part series on the SFO’s Cooperation Guidance: “Transparency” (Sep. 18, 2019); “Waiving Privilege” (Oct. 16, 2019); and “Internal Investigation Expectations” (Nov. 13, 2019).