On 9 October the SFO issued revised policies setting out its approach to the Bribery Act 2010. In three separate documents it issued guidance on facilitation payments, corporate hospitality and self-reporting. The new policies which replace existing guidance state that the SFO will prosecute cases of bribery where there exists sufficient evidence to do so except when prosecution is not in the public interest. For the full guidance see here and for a fuller analysis of the implications of the new guidance see here.

JD VIEW—Many media commentators have seen the new guidance as signalling a tougher approach from the SFO. In truth it may be more a change of emphasis than a shift in the approach taken to tackling overseas corruption.