On Monday the U.K. Serious Fraud Office announced its first deferred-prosecution agreement entered into under the Bribery Act. It involved the British banking institution ICBC Standard Bank Plc. The bank was charged with failing to prevent the payment of a bribe obtain business from the government of Tanzania.

According to the SFO press release, the bank made a $6 million payment to “induce members of the government of Tanzania, to show favor to Stanbic Tanzania and Standard Bank’s proposal for a U.S. $600 million private placement to be carried out on behalf of the Government of Tanzania. The placement generated transaction fees of U.S. $8.4 million.” As a result of the DPA, the bank was fined $25.2 million, paid the government of Tanzania $7 million in compensation and reimbursed the SFO £330,000 for its costs.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...