Bribery Act & Proceeds of Crime - Written by on Sunday, March 4, 2012 5:02 - 0 Comments

Days numbered for the Flat Earth Society: SFO lays out its Bribery Act activity since July 1

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One question on the tip of many tongues at the moment is when will the SFO take action in relation to Bribery Act offences.

In fact, as we disclosed back in November 2011, Bribery Act activity has already started.  Speaking to an audience in our offices Richard Alderman, the Director of the SFO said:

“…there is already Bribery Act activity by the SFO.  It is not out there in the public domain because our approach is to corporations and the work we are doing with them at this stage must inevitably remain confidential…”

“We are finding suspicions of bribery after July 1st by various corporations.  What we have been doing in a few instances is inviting the corporation to come and talk to us …”

Of course this is very much under the radar and there will be some (in denial) who refuse to believe it.  For those optimists who take the view that the various thinly veiled threats issued by the SFO are more akin to the boy who cried wolf recent SFO statements should be carefully studied.

Speaking in the last few days the Director said this in relation to Bribery Act activity:

  • “…A number of companies have already been to see us to say that they have uncovered post Bribery Act corruption.  We have been talking to them about internal investigations following our self-reporting guidance to corporates…
  • …There are some cases that we have identified ourselves where we are using our statutory powers to obtain evidence for the investigation…I shall be very surprised if we do not get some good cases out of this…
  • …We are also looking at a range of other leads that we have been given…
  • …And, of course, we are carrying on with the extensive work we are doing with corporations whether based in the UK or abroad in helping them rise to the challenge of the Bribery Act…
  • …We are also looking at issues relating to individuals…”

We met with the Director of the SFO last week.

At the end of our meeting and in passing we mentioned that, while we knew the SFO was active in the context of Bribery Act enforcement, there were many still waiting for the crowd pleasing raid and public enforcement action before the reality finally sinks in.

Smiling the SFO Director told us: “I know”.

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