Part 12 of the Anti-Terrorism, Crime and Security Act 2001 dealing with corruption came into force in the
UK on the 14th of February. The Act now means that any corrupt payment that would be unlawful in the UK is
now illegal if it is paid abroad, even if the payment is legal in the country concerned.
There are potential difficulties in interpreting the new law
however, and also practical problems in implementing it both for companies and government.
Parliamentary time will have to be found to address these difficulties and for the wholesale reform of UK
corruption law to take into account of the Council of Europe’s Criminal and Civil Law Corruption
Conventions which the UK is signatory to but has not yet ratified.
In addition, as part of the OECD’s peer-review process, the United States Foreign Corrupt Practices
Act will be reviewed by OECD members – led by UK and France – in early March.

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