Description:
The enactment of the Bribery Act 2010 in the UK is a significant development and requires the attention of any organisation that has any business in the UK for two key reasons.
- The extra-territorial effect of the Bribery Act means that U.S. entities and their officers will be at risk of prosecution in the UK even if their involvement in the UK is very limited. Indeed, this may be so even if no act related to the bribe occurred in its UK operations.
- The scope of the Bribery Act is in several respects broader than the FCPA. For example, the Bribery Act is not limited to the corruption of foreign public officials, and does catch both the recipients of bribes (unless the recipient is a foreign public official) and facilitation payments. Effectively, therefore, even non-UK companies will need to review anti-corruption efforts already in place to ensure that they comply not only with the FCPA, but also with the Bribery Act.
See full Press Release.