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The New UK Bribery Act

By Jonathan P. Armstrong

All General Counsel should reach for their calendars now and circle July 1. That's the date when the new UK Bribery Act will take effect. The Act has extra-territorial reach and will impact almost every corporation doing business internationally.

The UK's Lord Chancellor and Secretary of State for Justice Kenneth Clarke announced the start date for the new legislation on March 30. On the same day, the Ministry of Justice (MoJ) issued its final guidance on how a company should comply with the new legislation. At the same time, joint prosecutorial guidance was issued indicating who should feel the full weight of the legislation. The documents are lengthy. The MoJ's guidance stretches to 45 pages, with the prosecutors' guidance a further 12 pages. While much of the concentration has been on the MoJ guidelines, it is likely that the prosecutors' guidelines may have the most lasting significance.

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