Whilst attention continues to focus on the on-going absence of a corporate prosecution for bribery by the SFO, it is worth reflecting on the circumstances of the three individuals who have been convicted of offences under the Bribery Act 2010 in England:
1. Mr Patel, the court clerk.
2. Mr Mushtaq and the driving examiner.
3. Mr Li and the professor.… Continue Reading
It was reported in the Guardian newspaper, today, that two farmers, fed up with facing repeated demands to pay bribes, emptied three bags filled with snakes in a busy tax office in Basti, northern India.… Continue Reading
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