Following the enforcement of the Bribery Act 2010 (the Act), the FSA has confirmed that it too can impose sanctions against firms that fail to put suitable safeguards in place against corruption.

Whilst the FSA does not enforce the Act, it can take regulatory action against firms without needing to find evidence of corruption; it need only find that the firm failed to adequately assess the risk of corruption and put in place appropriate procedures to mitigate that risk. Firms do have a full defence if they can show they had adequate procedures to prevent bribery.

The FSA's warning serves as a reminder that firms need to adhere to the Act, as well as the separate regulatory requirement to assess corruption risk.