The Bribery Act 2010, which comes into effect in July 2011, is considered to be the beginning of an aggressive new stance by the UK on business misconduct. The Act casts a wide net and captures acts of bribery committed outside the country.

The new anti-bribery regime will have potentially alarming consequences for corporates with a presence in the UK because of the uncertainty surrounding its scope and application to international businesses. The Act has generated a lot of (often misleading) discussion and, while government has recently issued some highlevel guidance on its application, this has in many ways added to the confusion by simply advocating a ’common sense’ interpretation and leaving considerable discretion to the courts. This means that all businesses ought to be fully prepared for the increased risks and responsibilities that they will face under the new regime.

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