U.K. Practitioners Discuss the Prospect of Enforcement Actions Under the U.K. Bribery Act, Advantages of Deferred Prosecution Agreements and Proposed Sentencing Guidelines

What was all the fuss about?  The U.K. Bribery Act was adopted in 2010 and took effect in 2011.  Since then, there have been no prosecutions of corporations under the Act and only two formal investigations are known to be underway.  Experienced U.K. practitioners warn that the “fuss” may be proven justified soon, however, and companies should not be complacent.  In a recent webinar, experts cautioned that “enforcement is coming.”  They also discussed the availability of DPAs under the Bribery Act, the continuing utility of civil recovery orders and the proposed sentencing guidelines issued with respect to the Bribery Act.  This article summarizes the key lessons from the webinar.  See also “Strategies for Implementing the U.K. Bribery Act’s Requirement of Adequate Procedures for Intermediaries” (Feb. 6, 2013).

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