Like the U.S., the U.K. has been actively monitoring and enforcing anti-corruption efforts, having adopted the Bribery Act of 2010, which became effective in July 2011. The U.K. Ministry of Justice published a "Quick start guide" which summarizes the law's provisions. The Act contains four main offences: paying bribes, receiving bribes, bribing a foreign official, and commercial organizations failing to prevent bribery. Unlike the U.S. FCPA, the U.K. Bribery Act applies to both domestic and foreign corruption. Financier Worldwide summarized the political and legislative history of the Bribery Act. Background.
Last October, the U.K.'s Serious Fraud Office discussed three aspects of the Bribery Act: facilitation payments, business expenditure (hospitality), and corporate self-reporting. See SFO Press Release (with links to the guidance). The guidance, issued shortly after David Green was appointed Director of the SFO, restates the SFO's primary role as an investigator and prosecutor of serious or complex fraud, including corruption. In what appears to be a change in prosecutorial policy, the SFO notes in an accompanying questions-and-answers document that: "The revised policies make it clear that there will be no presumption in favour of civil settlements in any circumstances." It continues: "The SFO encourages corporate self-reporting, and will always listen to what a corporate body has to say about its past conduct; but the SFO offers no guarantee that a prosecution will not follow any such report." According to Law.com, these statements bring U.K. policy closer to that of the U.S., and lead some to question the value of self-reporting. Alignment.