With the Bribery Act 2010 coming into force on the 1st July, banks and approved firms need to be certain of their anti corruption policies, systems and controls. Bribery, whether committed in the UK or abroad, is a criminal offence. Authorised firms are under an additional, regulatory obligation to put in place systems and controls to mitigate corruption risk and to conduct their business with integrity. Whilst the SFO is currently the lead prosecutor for offences committed under the Act (including the corporate offence of failing to have adequate procedures to prevent bribery), the FSA will also be able to take enforcement action - penalising institutions for systems failures and potentially striking off authorised persons under whose watch the breach occurred. Under Principle 11, a “ firm must disclose to the FSA appropriately anything relating to the firm of which the FSA would reasonably expect notice”. This includes any activity which suggests there may have been bribery and corruption. Therefore firms need to be sure that they have robust systems and controls to prevent bribery and that no-one associated with the organisation offers illegal inducements, including facilitation payments or excessive or lavish hospitality. The FSAs “Financial Crime: A guide for firms” published as a consultation document on 22 June 2011 aims to provide guidance on best practice in combating bribery and corruption and draws on the FSAs thematic report “Anti-bribery and corruption in commercial insurance broking” that was published in May 2010. The FSA have already taken action in this area. In 2009, they fined insurance broker Aon Ltd £5.25 million pounds ($8.5 million) for failing to prevent a number of suspicious payments to overseas firms and individuals between 2005 and 2007. Banks and fund managers will clearly not be immune in future and the FSA will be looking for a high level scalp early on.