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Coming into Force — UK Bribery Act 2010 Delayed
Coming into Force — UK Bribery Act 2010 Delayed
V&E Foreign Corrupt Practices Act Communication, August 3, 2010
The long-awaited UK Bribery Act 2010 (which serves to overhaul and consolidate the previous UK offenses and legislation in this area) will have to be waited for slightly longer than expected.
Despite having made it onto the statute books this year, the UK Ministry of Justice has announced that the coming into force of the Bribery Act has now been pushed back to April 2011. It was previously expected to be implemented prior to October 2010.
Given the relatively apolitical nature of this act, it would seem unlikely that this is due to any change in policy as a result in the change in governments earlier this year. A more likely explanation may be the consultation that it has been announced for this autumn, during which the government will take soundings prior to issuing guidance notes regarding adequate procedures that commercial entities should take to be compliant under the new legislation.
Given the wide-sweeping nature of the offences contained under the new act, any such guidance can only be received with a warm welcome, as is the news that the government is willing to take into account the views of users in considering how to apply the potentially onerous and strict legislation.
A further point of speculation is whether this delay is in any way linked to the formative plans to introduce an Economic Crimes Agency, to investigate and prosecute serious financial offences — the scope and jurisdiction for which remains largely unclear at the time of writing.
For more information on the UK Bribery Act 2010, and as to how it might affect your business, contact Mark Beeley or Alex Msimang, London-based members of V&E's global Foreign Corrupt Practices Act group.
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