Subject to Inquiry

Subject to Inquiry


Government Investigations and White Collar Litigation Group

Tag Archives: “compliance programmes”

Anti-Bribery and Corruption, Compliance, Enforcement and Prosecution Policy and Trends

Facilitation payments: SFO creates its own guidelines

For those organisations that are doing their best to avoid making facilitation payments, but are finding it difficult to stop making them altogether, this insight into the SFO's thinking will offer some limited breathing room. However, the clear message from these six points is that the SFO will be expecting to see a positive approach by organisations towards the goal of eradicating such payments from their operations.… Continue Reading
Anti-Bribery and Corruption

Facilitation payments – to pay or not to pay: a difficult question?

Small, one off payments are, on their own, unlikely to attract the attention of the SFO. While there is no de minimis limit in the Bribery Act and therefore no guarantees with respect to low value payments, the fact remains that small infractions will not justify the time and cost involved in prosecuting. However, for those organisations that routinely make facilitation payments (even though each payment might itself only be small), there is a risk that continuing to make such payments will result in prosecution under the Bribery Act.… Continue Reading

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