Many have assumed (especially after the publication of the UK government guidance which cast doubt over whether a UK subsidiary or listing would sweep non-UK businesses into the Bribery Act net) that the activity of a sister company paying bribes in another country would not trigger Bribery Act liability for a foreign parent (or its UK subsidiary) and that as a result the SFO would be powerless to act. However it is clear that the SFO take a different view.
‘Enforcement 40’ for 2020
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