When I saw there was a press release from the UK's Ministry
of Justice, I was expecting an announcement of what it meant for a commercial
organization to have "adequate procedures" to prevent bribery. That being the
only affirmative defense under the Bribery Bill.
It turns out that...
The Bribery Act 2010 (the "Act") is due to come into
force in April 2011. The Act will see the introduction of the new "corporate
offence" of having failed to prevent bribery from occurring. The only defence
to this strict liability offence will be to demonstrate that the company...