The Anti-Bribery Act 2010 is now in force and criminalises any act by a United Kingdom citizen or resident to pay or receive a bribe, either directly or indirectly. The act provides for transactions that take place in the UK and abroad, and both in the public and private sectors.
Companies and partnerships can also commit an offence where a bribe has been paid on their behalf by an associate. Associates include employees, agents and other persons providing services on behalf of the corporate entity. However, it is a defence to have adequate procedures in place to prevent bribery.
When asked on Radio 4 Todays‘ programme if the Act would be aimed at ‘hospitality tents’ at Wimbledon, Vivian Robinson of the Serious Fraud Office said they would keep an eye on things there, but their aim was elsewhere. We now echo the US approach and will be prosecuting companies regardless of where the unlawful conduct took place.