And talking of delays, there have been various reports in the press of a delay to the Bribery Act 2010 (‘BA2010’) coming into force (although there is currently no official confirmation of this on the Ministry of Justice’s website).
The intention is for BA2010 to come into force three months after the issuance of guidance. The latter had been expected to be released in January with the Act taking effect this coming April.
This will be the second delay. Originally guidance was to be released last July giving us an October implementation date (see Regulatory Roundup 17 for further details).This was put back to April this year (as stated above).
As mentioned in Regulatory Roundup 21 it will be a defence for organisations (as per section 7 of BA2010) where ‘adequate procedures’ were in place to prevent bribery. The adequate procedures will stem from the guidance that is supposed to be issued (see section 9 BA2010). Complyport will work with its retained clients to ensure that suitable procedure are in place once the guidance is finally released.