New UK Bribery Law: Are You Ready?

Meeting the Requirements and Minimizing Corruption Risks Amid Heightened Scrutiny

New law goes into effect in April

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Thursday, February 10, 2011

Recorded event now available

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Course Materials

This CLE course prepare counsel for companies doing business in the United Kingdom to meet the demands of the new UK Bribery Act. The panel will outline effective compliance programs to minimize anti-corruption risks under both the new UK law and the Foreign Corrupt Practices Act.


The United Kingdom Bribery Act 2010, which goes into effect in April 2011, imposes liability on companies doing business in the UK whose employees or representatives engage in conduct considered to be bribery. The Act extends its jurisdictional reach to include acts of bribery outside the UK.

The Act dramatically changes the rules for companies doing business in the UK. It goes beyond the scope of the Foreign Corrupt Practices Act (FCPA), by including strict liability on any company that fails to prevent anyone performing services on its behalf from paying a bribe.

The Act provides a defense to liability if the company can demonstrate it had “adequate procedures” in place to prevent bribery from occurring. Companies and their counsel must therefore assess their current anti-corruption policies and implement compliance programs.

Listen as our authoritative panel reviews the requirements of the new Anti-Bribery Act and offers a comparison of the Act with the FCPA. The panel will also examine the UK's Ministry of Justice guidance and discuss strategies to ensure compliance with both the UK Act and the FCPA to minimize risks of violating either law.



  1. UK Anti-Bribery law and its requirements
    1. Who is covered and who is not
    2. Risks
    3. New offenses under the law
    4. Permissible and impermissible payments
    5. Books and records requirements
    6. “Adequate procedures” for affirmative defense
    7. Penalties
  2. Comparison with FCPA
    1. Who is covered
    2. Reach of the law
    3. Conduct covered
  3. Best practices for anti-corruption compliance
    1. UK Ministry of Justice guidance
    2. Elements of effective compliance program
    3. Mitigating factors
    4. Due diligence when working with third parties (agents, representatives, JV partners)
    5. “Adequate procedures” for affirmative defense


The panel will review these and other key questions:

  • Who is covered under the UK Anti-Bribery Act? How does the Act differ from the FCPA?
  • What is the extraterritorial reach of the UK Anti-Bribery Act?
  • What types of procedures are adequate to serve as a defense to liability?
  • What steps can companies take to minimize the corruption risks under the UK Anti-Bribery Act and the FCPA?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Monty Raphael
Monty Raphael

Special Counsel
Peters & Peters

He has been engaged in all aspects of litigation involving fraud and regulatory issues for more than 40 years and...  |  Read More

David S. Lorello
David S. Lorello

Steptoe & Johnson

He assists clients in investigating issues arising under the US Foreign Corrupt Practices Act and related US and...  |  Read More

James Barratt
James Barratt

O'Melveny & Myers

His practice covers international arbitration, white collar defense and corporate investigations and complex...  |  Read More

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