Compliance Communications Blog

"The Cost of 'Failing to Prevent'"


11/17/15: The October 2015 “FCPA Update” by law firm Debevoise & Plimpton contains a good chunk of useful information on several topics. The largest section is devoted to Brazil’s new guidelines for compliance programs – especially useful for companies with existing or planned operations... in that country – but the article starting on page 12 has broader significance. It applies to any company that comes under the jurisdiction of the UK Bribery Act, regardless of its location.   The Page 12 article focuses on a civil settlement between the Scottish Crown Office and Brand-Rex Limited. By highly publicized US standards, the settlement of £212,800 is barely a drop in the federal purse. What’s important about the case isn’t the size of the settlement but the liability of the company for failing to prevent bribery by an employee. This “corporate offence” distinguishes the UK Bribery Act from the US FCPA and many emerging anti-corruption laws. Head straight for Page 12 for the Brand-Rex article.

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