On March 30, 2011, the United Kingdom (“UK”) Ministry of Justice (“MOJ”) issued its long-awaited guidance on the UK Bribery Act (the “Guidance”). The implementation of the UK Bribery Act (the “Act”) has been delayed twice, but will now take place on July 1, 2011. Thus, the time has come for companies to assess their anti-corruption compliance programs and make adjustments to ensure that they address the nuances of the Act.
Effective Bribery Prevention Procedures
Section 7 of the Act creates strict liability for commercial organizations that fail to prevent bribery. Significantly, a company has a statutory defense to section 7 liability if it had “adequate procedures” in place to prevent persons associated with the company from engaging in bribery.
The Guidance identifies six principles that should guide organizations when formulating “adequate procedures.”
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