Britain’s Serious Fraud Office announced tough-talking new policies earlier this month on how it will enforce its new Bribery Act. The agency says it is now taking a harder line on facilitation payments and corporate hospitality, and providing fewer leniencies for self-reporting.
Mostly the changes are a matter of tone rather than substance, lawyers say. But the shift in tone is important nonetheless, they add. Companies will need to review whatever controls they have in place to ensure Bribery Act compliance. And those thinking about making voluntary disclosures to the SFO will have less certainty about how they might be treated.
