UK Law Enforcement

The Serious Fraud Office ('SFO') is the lead agency in England, Wales and Northern Ireland for investigating and prosecuting cases of domestic and overseas corruption. The SFO is responsible for enforcing the provisions of the Bribery Act 2010 (entered into force in July 2011) in respect of overseas corruption.

The Bribery Act 2010 completely repealed: (i) The Public Bodies Corrupt Practices Act 1889; (ii) The Prevention of Corruption Act 1906; and (iii) The Prevention of Corruption Act 1916; and partially repealed, revoked or amended other legislation.

NB: All offences pre 1st July 2011 will be dealt with under the previous legislation.

Other reference sources

• Guidance issued by the Ministry of Justice click-here
• Prosecution Guidance issued by SFO and the Director of Public Prosecutions click-here

See also:

The Bribery Act 2010
Associated Persons
The Regulator
Risk in current operations
Risk in new ventures and acquisitions
Red-Flags
Adequate procedures

An effective Compliance Programme reduces corruption risk when designed to prevent and detect violations or breaches before they occur. Such programmes include:

• Tone from the top - High level Policy Statement or Code of Conduct endorsed by senior management.
• Guidance - Compliance Manual with written standards and guidelines for all employees, contractors, agents, etc,.
• Accountabilty - Designated senior manager responsible for oversight, monitoring and compliance arrangements.
• Education - Training and awareness for directors, management, employees and relevant contractors / agents.
• Alert mechanism - Confidential telephone hotline for reporting details of suspected breaches.
• Assurance - Independent reporting to Senior Management (i.e. The Board) and the Audit Committee (e.g. Results of Internal Audit reviews/compliance-based testing).

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