United States:
FCPA Update: Implementation of U.K. Bribery Bill Postponed Until April 2011
To print this article, all you need is to be registered or login on Mondaq.com.
Implementation of the U.K. Bribery Bill (discussed in our
update of April 6, 2010) has been postponed for nine months
while the government evaluates comments to the Bill raised by
various business constituencies. The delay in implementation has
been viewed as a setback to U.S. efforts to achieve a global
approach to combating fraud. As currently drafted, the Bill is
potentially one of the toughest anti-bribery laws in the world and
would apply to any U.S. company doing business in the United
Kingdom. The Bill differs from the FCPA in several important
respects including the elimination of the "facilitating
payment" exception and imposition of a presumption of criminal
liability on an organization whose employees, agents or consultants
engaged in bribery to further the organization's business.
Commentators believe the delay in implementation may result in a
watered-down version of the law.
Look for additional updates on the progress of the Bill and
suggestions for compliance procedures.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
POPULAR ARTICLES ON: Finance and Banking from United States
Asset Recovery Comparative Guide
Bird & Bird
Asset Recovery Comparative Guide for the jurisdiction of UK, check out our comparative guides section to compare across multiple countries
FCA's Consultation Paper
Cadwalader, Wickersham & Taft LLP
Since 3 January 2018, firms that provide portfolio management or investment advice on an independent basis must pay for the research they obtain...
Regulation Round Up
Proskauer Rose LLP
Welcome to the UK Regulation Round Up, a regular bulletin highlighting the latest developments in UK and EU financial services regulation.
FCA To Permit Research Bundling
Akin Gump Strauss Hauer & Feld LLP
The Financial Conduct Authority (FCA) is seeking views on proposed rules that would allow asset managers to opt for bundled payments for third-party investment research, reversing a significant aspect of the UK's implementation of research rules under the Markets in Financial Instruments Directive (MiFID II).