The corporate community has become accustomed to the US authorities frequently investigating and prosecuting offences under the US Foreign Corrupt Practices Act (FCPA). Until recently, the same could not be said about investigations and prosecutions by the UK authorities. In part, the historic failure to investigate and prosecute corruption offences has been attributed to a lack of impetus by the Serious Fraud Office. However, to some extent, the lack of action has been a result of the antiquated and piecemeal nature of the UK law on bribery and corruption.

However, with the enactment of the Bribery Act when it arrives, with its wide-ranging changes and significant extra-territorial reach, one of the impediments will be that the bringing of successful prosecutions will be reduced.