The UK government generally implements the anti-corruption framework effectively (HRR 2016). The UK Bribery Act establishes criminal offenses for bribing (giving, promising and accepting) foreign public officials and bribery between businesses, and the offenses are enforceable against acts committed around the globe. Trading in influence, embezzlement, and abuse of function are also criminalized under the Act. Criminal offenses apply to companies and to persons, and it is an offense when companies fail to prevent corruption. Businesses can be held responsible for persons acting on their behalf, including employees and third parties. The Bribery Act provides companies with a full defense if a company can document ‘adequate procedures’ to prevent corruption prior to an offense. The Ministry of Justice has published the Quick start guide, which references the Business Anti-Corruption Portal, and the more detailed Guidance to the Bribery Act, which can assist companies in adopting ‘adequate procedures’ to prevent bribery. There is no exception for facilitation payments, and small-value payments, gifts, and hospitality may be illegal depending on their intent and benefit obtained. Sanctions for violating the Bribery Act include unlimited fines, imprisonment of up to ten years and debarment from public contracts. The Civil Service Code prohibits the acceptance of gifts or hospitality by civil servants which compromise their personal judgment or integrity. The Proceeds of Crime Act (POCA) allows authorities to confiscate the proceeds of crimes, including corruption offenses. Related UK legislation includes the Fraud Act and Money Laundering Regulations, which apply to a number of business sectors, including financial and credit businesses, accountants and estate agents. Whistleblowers are protected by the Public Interest Disclosure Act, which covers public and private sector employees. Corruption risks that lay with lobbying include the absence of requirements on lobbyists to report their expenditures on lobbying, including gifts and hospitality to public officials, the lack of limits set on political party donations, the permission of legislators to retain conflicts of interest as long as these are declared, and the allowing of legislators and civil service officials to meet with lobbyists without needing to report the meetings (TI, Feb. 2015). The OECD has commended the UK on its increasing enforcement of foreign bribery offenses (OECD 2017). The OECD does call on the UK to further improve inter-agency cooperation and to ensure the Serious Fraud Office (SFO) has the proper resources it needs to continue its enforcement actions (OECD 2017).
The UK is a signatory to the OECD Anti-Bribery Convention, the United Nations Convention Against Corruption (UNCAC), the Council of Europe’s Civil and Criminal Law Conventions against Corruption and is a member of the Group of States Against Corruption (GRECO). The UK has published an Anti-Corruption Strategy 2017-2022.