Recently the FSA has started a major campaign to sharpen up compliance with the new Bribery Act. In this country we tend to be rather complacent about bribery, safe in the knowledge that there is less of it here than in almost any other country except Greenland. The FSA is determined to cajole the industry out of that complacency, and is using quite large boots to achieve it. Having fined Willis a few months ago for lack of anti-bribery controls, the FSA is now touring the bars looking for further suspects. There must be a good chance that they will have little difficulty in finding firms that have done little or nothing about the new requirements. The very fact that FSA now proposes to update the Bribery chapter in its very new Financial Crime Guide shows that they are developing their strategy at this point, gathering new evidence and recognising where they have not been sufficiently specific hitherto.

The points made in the recent press notice in which FSA announced the outcome of their early thematic review ( FSA review into anti-bribery and corruption systems and controls in investment banks and proposed new guidance for all firms ) include that the majority of firms in their sample, in relation to implementing anti-bribery controls, “had more work to do”. This rather elegant understatement was emphasised by the list of common weaknesses, which included that “most firms had not properly taken account of our rules covering bribery and corruption, either before the implementation of the Bribery Act 2010 or after”.

Firms which suspect that they too might have a little more work to do may wish to get in touch.