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International

Jun. 1, 2011

A Closer Look at the 2010 UK Bribery Act

The Ministry of Justice's guidance to the 2010 U.K. Bribery Act may not be perfect, but it provides clues as to how liability will be determined. By Mike Emmick and Bethany Hengsbach of Sheppard Mullin Richter & Hampton LLP


By Mike Emmick and Bethany Hengsbach


LAST IN A TWO-PART SERIES: Part one appeared on Friday.


The Ministry of Justice's recently-issued guidance on the UK Bribery Act has received mixed reviews. Some companies were disappointed in the guidance's vagueness about what measures would help establish the new defense of having "adequate procedures" in place to prevent bribes. Other companies were pleased at the guidance, especially its clarifi...

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