As corporate lawyers have been waiting patiently for the U.S. Department of Justice to issue updated guidance on the Foreign Corrupt Practices Act, the United Kingdom’s Serious Fraud Office came out with some unexpected guidance of its own, clarifying how prosecutors on the other side of the Atlantic will prosecute bribery.
The guidance addresses three primary areas: facilitation payments, business expenditures (such as hospitality and gifts), and self-reporting.
‘Enforcement 40’ for 2020
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