UK Bribery Act

The UK Bribery Act 2010 is considered one of the world's most stringent anti-corruption statutes. It applies to any company with a UK presence or conducting business in the UK, regardless of nationality. It criminalises both paying and receiving bribes — including in private sector transactions (unlike the FCPA, which focuses on foreign public officials) — and creates automatic corporate liability for companies that fail to implement adequate anti-bribery prevention procedures. In international M&A, the Bribery Act is a significant risk vector for acquisitions involving companies with UK activities or links to UK entities.

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Example: during due diligence on a Swiss industrial group with a London commercial subsidiary, a UK Bribery Act compliance review identifies CHF 220,000 of undocumented "commissions" paid to a UK commercial agent. This finding leads to negotiation of specific representations and a dedicated escrow in the SPA covering potential Bribery Act liability — protecting the acquirer from inherited criminal exposure.

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Hectelion integrates UK Bribery Act compliance review in due diligence mandates involving targets with UK activities or relationships.