On 31 January 2011, the United Kingdom Ministry of Justice
confirmed a further delay in the implementation of the UK Bribery
Act (the Act). The Act, which was scheduled to come into effect in
April 2011, has been delayed pending the publication of guidance
designed to enable business organisations to prepare for the new
regime, particularly in relation to the procedures that
organisations should adopt in the context of the new corporate
offence of failure to prevent bribery. The Act is presently
scheduled to come into effect three months after the guidance has
been published. The Ministry of Justice has not announced when the
final guidance can be expected.
This latest delay follows the UK government's July 2010
announcement that it was postponing the Act's implementation
until April 2011 to allow businesses time to prepare for its
effect. In September 2010, the Ministry of Justice issued draft
guidance relating to the Act and initiated a two-month
