UK Boosts Anti-Corruption Enforcement Efforts

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The UK’s Serious Fraud Office (SFO) is launching an investigation into whether claims of corruption by a former Rolls-Royce employee have any merit. Among the allegations is the assertion that Rolls-Royce gave Tommy Suharto, the son of a former Indonesian dictator, $20 million and one of its automobiles in exchange for his help in convincing Garuda, the country’s flag-carrying airline, to buy the company’s aircraft engines. In a letter to the SFO, Mr. Suharto has denied receiving any bribes from Rolls-Royce.

In late 2012, Rolls-Royce self-reported the alleged incidents of corruption to the SFO after conducting an independent investigation. Since then, the SFO has requested and obtained additional funding from the UK Treasury to cover the costs of its own investigation against Rolls-Royce. It is not yet clear, however, whether the agency will pursue prosecutions under the UK Bribery Act. But even if this case does not result in formal charges against Rolls-Royce, the SFO has clearly shown its willingness to conduct complex investigations and — in the right cases — move forward with prosecutions.

In another recent UK bribery case, the Financial Conduct Authority (FCA) fined insurance broker JT Specialty £1.8 million for failing to adhere to the firm’s anti-corruption measures prior to submitting payments to overseas entities for the introduction of new business. The FCA found that JT Specialty neglected to investigate whether these entities had any corrupt ties to public officials and/or the clients being introduced before entering into a relationship with them. As a result, JT Specialty recklessly assumed the risk that any payments it made could be used to pay bribes or engage in other corrupt business practices.

The recent crackdowns on bribery in the UK should send a message to all organizations about the need to be vigilant in enforcing anti-corruption policies. This includes conducting regular training for all employees.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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