Barry and Richard write on one of our favourite blogs (FCPA Blog) about UK anti-money laundering laws where an offence under the Proceeds of Crime Act (POCA) may still be committed even if the organisation has a defence under the Bribery Act.

The outcome: even more severe penalties (14 years in jail instead of 10) than those under the Bribery Act…

We encourage all our readers to follow www.fcpablog.com. While the UK Bribery Act is different to the US Foreign & Corrupt Practices Act (FCPA) the Bribery Act has the FCPA in its DNA.

Investigations underway in the US (for example those into the pharmaceutical industry) and the historical approach of the US courts in this area are a useful indicator of factors UK courts may take into account when applying UK legal principles to prosecutions under the Bribery Act.