New SFO Bribery Act policies: What will they mean for corporates in practice?


On 9 October the Serious Fraud Office (SFO) released its revised policies on facilitation payments, corporate hospitality (business expenditure) and corporate self-reporting. The new policies are stated to have immediate effect and supersede any statement of policy or practice previously made by or on behalf of the SFO in these areas.

Most notable are the revisions to the SFO’s policy on self-reporting which is where the greatest departure from its previous position appears to lie.

The revision of policies in respect of corporate hospitality and facilitation payments are also notable, particularly given these were areas in relation to which concern was expressed by some corporates when the Bribery Act first came into force and where subsequent guidance and public statements by the SFO had provided some comfort.

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