Corruption: a new construction

Mere months later (although admittedly after a lengthy investigation), the SFO announced that it had obtained its first such success – a civil recovery order for UK£2.25m against Balfour Beatty plc for “inaccurate payment records arising from certain payment irregularities.” This was a ground-breaking move, and the use of civil powers to settle potentially criminal matters mirrors one of the more positive elements of US justice. So where does it leave a business that operates internationally?

Edward de la Billiere is Head of Financial Investigations and Criminal Fraud, Hill Dickinson LLP: direct line (London): +44 (0) 20 7280 9200, direct Line (Manchester):+44 (0) 161 235 7530; email: Edward.DeLaBilliere@hilldickinson.com

The law on bribery and corruption is still confusing for companies, drawing as it does on both new and ancient legislation, the common law, and all of this combined with modern day reporting duties under the Proceeds of Crime Act 2002 (POCA).