Prosecutions brought under the UK Bribery Act have become a
serious and costly concern for companies across industries,
including food and beverage manufacturers and distributors, that
operate or associate with business partners in the UK.
Deferred Prosecution Agreements
The UK Serious Fraud Office (SFO) has a number of matters under
consideration, including some to which the UK Bribery Act would
apply. It seems likely that the SFO may be holding off on some
decisions regarding disposal until Deferred Prosecution Agreements
(DPAs) become an available option in the UK.
The SFO will be able to agree to the disposal of appropriate
cases by way of DPAs from early 2014. The process will be similar
to that which applies in the U.S., with the important exception
that the process will be the subject of judicial scrutiny from the
outset. In approaching DPAs, the SFO has indicated that it will
look at each individual case in the round, taking full account of
the strength