At Compliance Week 2011, K.C. Turan, chief compliance and privacy officer for Dun & Bradstreet, explained that his company had revised its anti-corruption program to make the heightened standards of the U.K. Bribery Act its default standard.

For example, the Bribery Act prohibits facilitation payments while the FCPA does not. Turan said that D&B now explicitly prohibits facilitation payments, and has also expanded its prohibition on bribery to include requesting or agreeing to receive or accept bribes to track the stricter Bribery Act.

It appears that other companies are beginning to take the same approach. The WSJ's Corruption Currents blog noted that on Monday, Lockheed Martin Corp. filed a Form 8-K disclosing changes to its internal "Compliance with the Anti-Corruption Laws" policy in light of the new law. The new corporate policy, which can be viewed here, cites to several of the key provisions of the Bribery Act that vary from the FCPA, and notes the company's objective to have corporate policy align and comply with the new law. Thus, Lockheed also now prohibits facilitating payments, for example.

A Lockheed spokesman told the WSJ that the changes “updated and globalized” company policy “to promote compliance with the U.K. Bribery Act” as well as the FCPA. The new Lockheed policy takes effect June 16, two weeks before the UK Bribery Act's July 1 effective date.