The British Bankers’ Association (BBA), the trade association for the U.K.’s banking and financial services sector, has recently refreshed its guidance on the steps that banks should take to comply with the U.K. Bribery Act 2010.  Despite its industry focus, the BBA Guidance contains a number of recommendations that will be valuable to any large company when implementing an anti-bribery compliance program.  In a guest article, Jeremy Cole and Alex Hohl, consultant and senior associate, respectively, in Hogan Lovells’ London office, provide a recap of some of the key features of the Bribery Act and consider the role of the U.K.’s financial regulator in pushing companies to take the implementation of anti-bribery measures seriously.  They also examine the BBA Guidance, which not only builds on the official guidance on anti-bribery compliance published by the U.K.’s Ministry of Justice in March 2011, but also looks beyond the Bribery Act to take into account the requirements that the U.K.’s regulatory regime places on financial institutions in this area. See “Corruption Risks and Anti-Corruption Strategies in the E.U.” (May 14, 2014).