Introduction

Welcome to this special 10th anniversary edition of our UK Bribery Digest, covering the most notable cases and trends observed since we began our analysis of cases in April 2008 just over a decade ago.


It feels like a long time ago when we reflect that in 2008 we were anticipating the UK Bribery Act being introduced and predicting its effects. Since then we have seen three Directors lead the Serious Fraud Office (SFO) and have seen many parts of the world enhance their own anti-bribery laws while the US has continued to evolve its enforcement of the FCPA. It is a different legislative, enforcement and risk landscape that businesses now face.


This Digest has now reported on 86 cases covering the period up to December 2018 with some emerging patterns and trends which we highlight. It has been fascinating to observe and contribute to the changing tides of informed opinion surrounding these cases and anti-corruption compliance efforts more generally, and to note how these have altered the course of the organisations trying to navigate their way through uncertainty.


Since the end of 2018 there have been cases and decisions which have again caused shockwaves — the announcements not to prosecute individuals in some of the SFO’s high profile cases, and the admission of a senior sales executive to 11 counts of bribery. We look forward to bringing our commentary to you as these cases develop.


As ever, we dissect and comment upon the recent completed cases and set out an updated table of all the cases previously covered in the Digest.

I hope you continue to find the UK Bribery Digest insightful and useful in your work.


Please do not hesitate to contact me if you would like to discuss any of these issues further or make comment.


Jonathan Middup
Partner, UK Head of Anti-Bribery and Corruption
Forensic & Integrity
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