Whither the UK Bribery Act?

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2 Responses

  1. Bill Wilson says:

    Regardng your comments about “it is hard to get a company’s attention on UK Bribery Act risks when the message out of the United Kingdom vacillates” I suggest that compliance officers remember that virtually everything that the UK Act prohibits can be prosecuted under Federal or state US law, depending on the facts. Thirty six states have statutes, 18 are felonies if the circumstances are right, and the Feds have several statutes (mail/wire fraud, Travel Act, etc.) at their disposal. So there should be more than enough incentive, regardless of how the SFO sorts this matter out.

  2. David Greene says:

    Of course, how the U.S. proceeds with its own program, which has been pretty seriously enforced to date, will depend on the outcome of the upcoming election and any changes in policy/direction that come from that outcome at the Department of Justice and the SEC. As Mr. Wilson points out, there is a significant framework in place in the U.S. at both the Fed and state level. The policy following the election on actual enforcement and whether there will or will not be areas of enforcement focus/intiatives will be the rub. At least the Justice Department won’t be concentrating on Roger Clemens next year.