Should corporates that are tempted to self-report to the SFO look away now?
David Green CB QC, the director of the SFO, has issued revised SFO policies concerning facilitation payments, business expenditure (hospitality) and corporate self-reporting. The new policies were published on 9 October 2012.
The new policies can be summarised as follows:
Facilitation Payments Policy - They are illegal; decisions to prosecute will be based on the Prosecutor's Code (the "Code") and the Joint Guidance (the "Guidance") and the making of these payments may lead to prosecution under the Bribery Act 2010 and/or the Proceeds of Crime Act 2002.
Gifts and Hospitality Policy - They may be legitimate expenditures but they may also be bribes; decisions to prosecute will be based on the Code and the Guidance and the making of these payments may lead to prosecution under the Bribery Act 2010 and/or the Proceeds of Crime Act 2002.
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