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In the second part of our examination into the ramifications for businesses affected by the UK Bribery Act 2010 (the Act) (which came into force on 1 July), we examine what procedures a commercial organisation coming within the Act should adopt to provide it with a defence that it has adequate procedures in place to prevent bribery.
The UK Bribery Act 2010 (Act) came into force on 1 July. It seeks not only to combat bribery in the UK but has a wider territorial reach and is much more far-reaching than the US Foreign Corrupt Practices Act 1977. The UK Serious Fraud Office (SFO) has already stated that "the UK will have the toughest bribery legislation in the world and it will be vigorously enforced…" This chilling statement has now been backed by action by the UK Crown Prosecution Service (CPS) with the first conviction under the Act.
It has been another unusual year, and although many clients continued to face difficult markets, an increasingly large proportion have been thriving. Has a corner been turned? We don't think so yet - but the signs are encouraging, and we have begun 2011 with great optimism.
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