Policy & procedures

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Under the Bribery Act 2010 (BA 2010) it is an offence to pay or receive a bribe. In addition, BA 2010 includes two offences designed to target commercial bribery:

  1. •

    an offence of bribing a foreign public official

  2. •

    a separate corporate offence of failure to prevent bribery

The corporate offence can be committed by a commercial organisation where a bribe is paid by a person associated with it with the intention of obtaining or retaining business or business advantage for the organisation—see Practice Notes: The Bribery Act 2010—an introductory guide and Failure to prevent bribery—the offence.

An organisation can also be criminally responsible for a bribery offence committed by a senior manager of the organisation where that senior manager was acting within the scope of their authority—see Practice Notes: How to manage corporate criminal

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Latest Practice Compliance News

FATF announces new mutual evaluation framework to strengthen global illicit finance defences

The Financial Action Task Force (FATF) has convened  its annual high-level meeting with the nine FATF-Style Regional Bodies (FSRBs) in Strasbourg, announcing the implementation of new mutual evaluations. The Global Network, comprising the FATF and nine FSRBs, representing over 200 jurisdictions, remains committed to combating illicit finance through a unified set of standards and mutual evaluations. The meeting focused on implementing Global Network priorities, particularly preparing members for the upcoming mutual evaluations, which will prioritise effectiveness in tackling money laundering, terrorist financing and proliferation risks. All FSRBs aim to complete their first evaluations by late 2026 or early 2027. Additionally, significant emphasis was placed on fostering peer learning, experience sharing and strengthened cohesion within the Global Network, a key priority under the Mexican Presidency.

ICO publishes guidance documents and work plan for Data (Use and Access) Act 2025

The Information Commissioner's Office has published several guidance documents and a working plan following the Data (Use and Access) Bill receiving royal assent on 19 June 2025 and becoming an Act of Parliament as the Data (Use and Access) Act 2025 (DUAA). The ICO notes that the main changes to the law include clarifying how personal information can be used for research, lifting restrictions on some automated decision making, setting out how to use some cookies without consent, allowing charities to send people electronic mail marketing without consent in certain circumstances and requiring organisations to have a data protection complaints procedure and introducing a new lawful basis of recognised legitimate interests. The ICO also underlines that the DUAA provides it with new powers including the ability to compel witnesses to attend interviews, request technical reports, and issue higher fines.

Data (Use and Access) Bill receives Royal Assent on 19 June 2025

The Data (Use and Access) Bill (DUA) received Royal Assent and became an Act of Parliament on Thursday 19 June 2025. This followed its parliamentary review being finalised on 11 June 2025 and marked the culmination of nearly eight months of parliamentary procedure. Under section 139 of the DUA, most provisions will come into force as and when the Secretary of State appoints regulations. However, a limited number of provisions came into force upon Royal Assent. This included section 78, which relates to reasonable and proportionate searches for data subject access requests. It also included sections 126–128 on the retention of biometric data, and schedule 16 on the grant of energy smart meter communication licences.

Practice Compliance weekly highlights—19 June 2025

This week's edition of Practice Compliance weekly highlights includes: the latest Practice Compliance forecast, notable financial sanctions developments, progress on the Data (Use and Access) Bill, and important updates on OFSI licence adjustments.

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