UK Anti-Bribery Act: Meeting the Tough New Requirements

Minimizing Corruption Risks Under Both the FCPA and UK Law

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

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Conducted on Wednesday, June 9, 2010

Recorded event now available

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Course Materials

This CLE course will prepare counsel to companies doing business in the United Kingdom to meet the demands of the new Anti-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.


In April 2010, the long-awaited United Kingdom anti-bribery bill became law. The Bribery Act 2010 imposes liability on companies doing business in the UK whose employees or representatives engage in 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. The law 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. It is important for companies to assess their current anti-corruption policies and implement compliance programs.

Listen as our authoritative panel reviews the requirements of the new Anti-Bribery Act, compares and contrasts the Act with the FCPA, and discusses strategies to ensure compliance with both the Act and the FCPA to minimize risks of violations of either.



  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. Elements of effective compliance program
    2. Mitigating factors
    3. Due diligence when working with third parties


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?


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

Tom Sprange
Tom Sprange

Steptoe & Johnson

He conducts internal investigations, audits, and risk assessments for clients in the context of regulatory compliance,...  |  Read More

Lichtenbaum, Greta
Greta Lichtenbaum

O'Melveny & Myers

Ms. Lichtenbaum's practice principally relates to regulations governing international business transactions and...  |  Read More

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