Guidance on Bribery Act issued by the British Bankers Association

Guidance on Bribery Act issued by the British Bankers Association

The British Bankers’ Association recently published guidance on compliance with the Bribery Act 2010. It sets out the key issues for the UK banking sector to consider in implementing the Act.

The Bribery Act introduced a specific corporate offence of failure to prevent bribery, and companies can defend themselves against the allegation that they failed to prevent bribery from occurring by showing that they had “adequate procedures” in place to prevent bribery. The Act itself does not define “adequate procedures”, but Government guidance has been produced which sets out principles and good practice examples to follow. However, ultimately it will be for the courts to decide, in any given case, whether procedures that were in place at the time were adequate to prevent bribery.

The BBA guidance is not a substitute for the Government guidance, but is designed to be read in conjunction with the Act and other relevant guidance (including that produced by the Government and the FSA). It is intended to support banks in helping them assess how to approach the establishment of adequate policies and procedures to meet the requirements of the Act, and how that may link with other regulatory requirements such as FSA regulations.

For a link to the BBA guidance, please visit

For further information or advice about The Bribery Act please see our briefing notes or contact Beverley Flynn on 01483 734264 or email

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