The Act will apply to all companies who carry on business in the UK.
It is not too late to establish the corporate defence of having adequate procedures to prevent bribery provided that establishing such procedures begins as soon as possible.
Despite some uncertainty over its future the Serious Fraud Office (SFO) will remain the chief enforcer of the Act for at least the next year (and possibly much longer) until a UK government review is concluded.
The SFO has recently given useful guidance in relation to its attitude to small facilitation payments. Concern had been expressed by some companies that a complete zero tolerance to facilitation payments would mean that they could be forced to move business from certain parts of the world because they could not effectively conduct business there without paying them. In a speech on 9 June 2011, at the Russia Legal Seminar in London, Richard Alderman, the Director of the SFO, said...
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