Introduction When was the last time your anti-corruption compliance program had a check-up?  Like any other “wellness” program, a periodic review of a company’s compliance program is an integral component of its overall health.  As with many of us who delay personal health check-ups, a compliance check-up is often put off until a problem arises, at which point a significant … (read more)

1. 2011 HIGHLIGHTS Coming into force in July 2011, the UK Bribery Act 2010 (the “Act”) brings corruption in international business to the forefront as corporations endeavour to remain compliant with varied anti-corruption legislation around the world. Although only recently effective, the Act is perhaps the most far-reaching anti-corruption legislation enacted to date, and already has caused and is expected … (read more)

I.  Background The recent fine of £6.895 million levied by the UK’s Financial Services Authority (“FSA”) against insurance broker Willis Limited, a subsidiary of Willis Group Holdings, (“Willis”) represents the largest penalty imposed by the FSA in its history for inadequate financial crime systems and controls. The action, which pre-dates the effective date of the UK’s Bribery Act 2010 (the … (read more)

Ethisphere recently spoke with Homer E. Moyer, Jr., FCPA expert at Miller & Chevalier, to discuss the expected impact of the new UK Bribery Act on multinational companies and to answer questions on the uncertainty of future anti-corruption regulation. E: Now that the UK Bribery Act appears to actually be ready for implementation, will the DOJ react and become even … (read more)

The new UK Bribery Act (the “Bribery Act” or the “Act”), which received Royal Assent on April 8, 2010, has become the subject of significant discussion and debate both inside and outside the United Kingdom. The Bribery Act replaces the UK’s existing anti-bribery legal regime with a comprehensive new law that is, on its face, more restrictive than the U.S. … (read more)

This article considers the anti-corruption enforcement landscape in the UK. In recent years there has been a very significant stepping up of enforcement activity in this area which, coupled with its far-reaching new Bribery Act, will make the UK regime a real force to be reckoned with. Equally, two significant recent cases demonstrate the continued difficulties surrounding plea discussions with … (read more)