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The article explores lessons learned in the 10 years of enforcement of the UK Bribery Act — considered a landmark piece of legislation to boost corporate and executive convictions. It is noted that the Bribery Act has resulted in a dramatic increase in anti-bribery and anti-money laundering training in the professional and financial services sectors, resulting in firms and their employees taking a hardline stance on anti-bribery and corruption (ABC) issues. However, anti-bribery enforcement in the UK has been generally small, with the Serious Fraud Office (SFO) focusing on only a notable few cases. Bribery investigations also have led to an increase in the use of deferred prosecution agreements (DPAs), allowing organizations time to cooperate with the SFO and/or self report. Ultimately, the House of Lords may want to reexamine the efficacy of the Bribery Act to determine if change is needed.
Neil Robson’s article, “The Bribery Act: A Decade On,” was first published in Thomson Reuters Regulatory Intelligence, available online and via PDF.
London
