During the past few years, foreign companies increasingly have become the targets of bribery investigations and enforcement actions brought by the U.S. Department of Justice and the U.S. Securities and Exchange Commission. Indeed, the biggest anti-corruption enforcement action in history was brought under the Foreign Corrupt Practices Act (FCPA) against Siemens A.G., a German corporation with its main offices in Munich.

In response to the increased focus on anti-corruption in the United States, E.U. member countries such as the United Kingdom have begun to step up their own enforcement efforts.

Specifically, the U.K. Serious Fraud Office (SFO) has recently increased its efforts to enforce existing laws in the United Kingdom. In addition, there is a “Bribery Bill” pending in the U.K. Parliament that is similar to the FCPA in some ways and different in others. U.S. corporations would do well to pay attention to this emerging focus on bribery in the United Kingdom.

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