Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Bribery definition

What does Bribery mean? Bribery describes the offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage to induce or reward the improper performance of a function or to influence a person in a position of trust. In England & Wales, Scotland and Northern Ireland, bribery is principally governed by the Bribery Act 2010, which consolidated and reformed the law. It creates offences of active and passive bribery (sections 1–2), bribery of a foreign public official (section 6), and the corporate offence of failure to prevent bribery by associated persons (section 7), with a statutory defence of having adequate procedures....

SFO bribery enforcement: UK guidance on self-reporting, DPAs, corporate co-operation, adequate procedures, compliance programme evaluation, plea discussions, sentencing and whistleblowing

Published by a LexisNexis Corporate Crime expert

Practice notes

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SFO’s key policies on prosecuting Bribery offences

The Serious Fraud Office (SFO) is the principal authority investigating and prosecuting corporate bribery in the UK. In conjunction with the Crown Prosecution Service (CPS), it may enter into deferred prosecution agreements (DPAs) with organisations, allowing them to sidestep some of the impacts of a prosecution. For further detail, see Practice Note: Deferred Prosecution Agreements (DPAs). The SFO releases a range of policies and internal guidance that direct investigators and prosecutors handling bribery matters. Organisations, and those who advise them, should understand these materials as they illuminate the SFO’s stance on specific issues. The key SFO policies and guidance are:

the Ministry of Justice’s (MoJ’s) guidance on the Bribery Act 2010 (BA 2010)
the SFO’s Cooperation Guidance
the SFO’s guidance on Evaluating a Corporate Compliance Programme
the SFO’s guidance for whistleblowers

Collectively, this Practice Note refers to these as ‘the SFO policies’. As outlined in the SFO policies, decisions by the SFO to prosecute unlawful conduct are governed by:

the Code for Crown Prosecutors
DPAs Code of Practice
the Joint SFO-CPS

Taken together, these materials articulate the framework within which the SFO approaches corporate bribery prosecutions...

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Emily Agnoli

Simmons & Simmons

Emily joined Simmons & Simmons in 2008 and qualified into the dispute resolution team in London in 2010 where she is now a managing associate specialising in corporate crime. She has significant experience in advising corporations on high profile civil and criminal investigations in both the UK and internationally, including those run by the UK Serious Fraud Office, the Financial Conduct Authority, the Police and HMRC. Emily is a member of the firm's eDiscovery experts committee and has extensive experience of using electronic review platforms in large scale investigations and disputes. Recent Work ' advising a major FTSE company on a large scale corruption investigation involving the Serious Fraud Office, Financial Conduct Authority and US Department of Justice including advice on self-reporting and negotiations over remedial action with the Serious Fraud Office ' acting for a defendant in connection with a multi-billion dollar fraud claim covering five...

Web page updated on 21/05/2026

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