ARTICLE · 03 FEBRUARY 2011

Bribery Act 2010 Implementation Delayed

CMS Cameron McKenna Nabarro Olswang

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The Ministry of Justice has indicated that the Bribery Act 2010 will not be implemented in April this year, as previously expected, but will instead come into effect three months after publication of the Government’s final guidance on putting in place "adequate procedures" for the purpose of the defence to the corporate offence.

United KingdomGovernment, Public Sector

Omar Qureshi

Joe Smith

The Ministry of Justice has indicated that the Bribery Act 2010 will not be implemented in April this year, as previously expected, but will instead come into effect three months after publication of the Government's final guidance on putting in place "adequate procedures" for the purpose of the defence to the corporate offence.

Following a consultation on the draft guidance that ended in November last year (see our previous Law-Now), the final guidance was expected to be published in January 2011, in time to allow businesses to review their policies and procedures before April, when the offences were due to take effect. However, the Ministry of Justice ("MoJ") has now confirmed that there will be a delay in publishing this guidance and, as a result, there will be a three month delay before the offences created by the Act come into force. According to a spokesman for the MoJ quoted by the Financial Times:

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