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FCPA and Bribery Act Compliance

In recent years, Foreign Corrupt Practices Act (FCPA) and UK Bribery Act legislation have resulted in significant compliance concerns for companies conducting cross-border transactions and running global businesses. Under the UK Bribery Act, British firms may also be liable for acts of bribery by a third-party service provider anywhere in the world.

red24 and RISQ Worldwide have a team of anti-corruption, compliance and audit specialists which guides the construction, implementation and ongoing audit of programmes to help safeguard companies. The team works closely with top-level management, whose commitment is crucial to the success of these compliance programmes. Companies are now duty bound to implement these programmes to ensure their reputational risk.

As part of its initial guidance, the UK government published six broadly worded principles for bribery prevention. What is deemed ‘adequate’ will vary according to the nature of each company’s business and associated risks. The only defence available to accused parties is to show that they had ‘adequate procedures’ in place, although the onus falls on UK companies and citizens.

This process is hampered by cross-jurisdictional, cross-country boundary and cultural differences which may impair implementation and compliance of any programme promulgated by the parent company.

It is therefore incumbent on all UK companies and their employees to implement a robust compliance programme. Furthermore, it is essential that this programme is disseminated through the entire business and supply chain, including sub-contractors and their sub-contractors, on a worldwide basis.


red24 and RISQ Worldwide help implement anti-bribery procedures and compliance programmes for both the FCPA and the UK Bribery Act, through the following services:

  • Review and audit of company or individuals ‘adequate procedures’
  • Implementation of ‘adequate procedures’
  • Establishment of ‘whistle-blower’ hotlines
  • Investigation of corruption and bribery allegations
  • Preparation of prosecution and internal investigation files
  • Provision of expert testimony
  • Anti-corruption training