The recently enacted UK Bribery Act 2010 (“Bribery Act”), which will become fully effective and enforceable in Spring 2011, constitutes a sweeping revision and expansion of the United Kingdom's anticorruption legislation. It creates broad prohibitions on both public sector and commercial bribery for essentially any company or person with a connection to the United Kingdom.
The jurisdictional reach of the Bribery Act is otentially profound and generates the need for any
company with operations in the UK to closely valuate its anti-corruption compliance policies and procedures. In particular, under Section 7, the Bribery Act imposes strict liability on any company with a connection to the UK -- including those operating even a “part of a business” in the UK -- whose employee or agent commits a violation of the Bribery Act and where the company lacks "adequate procedures" to prevent bribery. Furthermore, the Bribery Act provides that a company's senior officials face personal liability if they consent to conduct that violates the Bribery Act. In short, the Bribery Act -- which provides for limitless fines for companies and 10 year prison sentences per violation for individuals -- demands immediate attention from the business world generally, but especially from any company with connections to the United Kingdom.
http://www.chadbourne.com/files/Publication/23d3c68a-721c-453e-8b5d-379049a8194c/Presentation/PublicationAttachment/932fae88-7778-4d3e-8069-45bb469522c6/CorpGov-%20UK%20Bribery%20Act_ca.pdf
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