Bribery Act 2010 Update: Delay to Implementation

In our August 2010 Client Memorandum we assessed the implications of the UK’s new Bribery Act 2010 (the “Act”) for organisations doing business in or from the UK. We noted that of particular significance to commercial organisations is the creation of a new strict liability criminal offence for failure to prevent bribery by a person associated with the organisation. The only defence to the new offence is for the organisation to prove that it had in place “adequate procedures” to prevent such payments from occurring.