BHP Billiton Ltd., the world’s largest mining company, has reportedly banned the use of facilitation payments to bring it in line with the Act, which came into force on 1 July 2011. The company had previously discouraged such payments, but they were not barred under the Foreign Corrupt Practices Act.

The London Metal Exchange has updated its policy for the approval of good delivery points for the storage of metal to bring it in line with the Act. Under the new policy, a description of the location’s corruption and bribery risk must be provided, which would include whether it has and enforces laws concerning corruption of foreign officials, whether facilitation payments are often demanded there and what, if any, the steps are to address it.