The UK anti-bribery statute — broader than the FCPA and includes a corporate offence of failing to prevent bribery.
The Bribery Act 2010 is the UK's principal anti-corruption statute. It creates four offences: bribing another person, being bribed, bribing a foreign public official, and — distinctively — the corporate offence of failing to prevent bribery (Section 7), which makes a commercial organisation strictly liable unless it can demonstrate "adequate procedures" to prevent bribery by associated persons.
The Section 7 strict-liability frame, together with extraterritorial scope (any UK-business nexus suffices), made the Bribery Act materially stricter than the FCPA in several respects. The "adequate procedures" defence has become the template against which corporate anti-bribery programmes worldwide are designed and audited.
Babieca covers the third-party-payment, agent-commission and kickback patterns that "adequate procedures" programmes are expected to surface — relevant for listed and pre-IPO European companies with UK exposure.
