The UK's anti-corruption enforcement has, of late, not been as active as it once was. Over the last few weeks, however, the space has charged back into life with two new investigations by the SFO announced, 14 convictions secured, and new corporate guidance for DPAs. The below is a timeline of the activity from the last few weeks:
17 April – The Serious Fraud Office announced it has charged United Insurance Brokers Limited with failure to prevent bribery under the Bribery Act in relation to alleged bribes paid by US intermediaries in Ecuador in return for US$38million in contracts.
24 April – The Serious Fraud Office announced revised Guidance for corporate self-reporting and cooperation as means to achieve a deferred prosecution agreement rather than criminal enforcement. As a headline the Guidance states that a self-reporting company will be invited to enter into a DPA "unless exceptional circumstances apply".
28 April – The Crown Prosecution Service secured four convictions for bribery in the construction sector, with the bribes valued at £600,000 paid between 2012 and 2018. Three of the convicted were sentenced to three and a half years in jail, and the fourth to two years.
29 April – authorities in Scotland secured four bribery convictions (two bribe payers and two bribe receivers). The bribes were valued at £88,000 and took the form of cash, gifts and hospitality. The value of the contracts obtained, involving numerous National Health Service rusts, was over £5.7m. Sentencing is due to take place in June.
30 April – The Serious Fraud Office announces raids and arrests as part of the investigation into the British company Blu-3 which is accused of paying £3m in bribes in relation to the construction of a data centre in the Netherlands.
1 May – The Crown Prosecution Service obtained six convictions for bribery offences for bribes paid between 2011 and 2015 in the form of money, cars, holidays and other benefits. The recipients started taking the bribes while at E.ON and continued to do so once they had moved to British Gas. The bribes were paid to secure contracts in relation to new build projects. The recipients were sentenced to 3 years and 10 months and 2 and a half years respectively, while the wife of one of the recipients was given a 13 month suspended sentence. The bribe payers were sentenced to four years, 2 years and five months and 12 months respectively.
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