The United Kingdom Bribery Act “went live” in July 2011 (approximately 14 years ago).
At the time, it was described by some as the “FCPA on steroids.”
Over the past 14 years, the U.S. (either DOJ/SEC or both) have resolved 12 Foreign Corrupt Practices Act enforcement actions against United Kingdom companies.
Those actions are as follows.
- Tysers Insurance Brokers (2023)
- H.W. Wood (2023)
- Rio Tinto (2023)
- Glencore (2022)
- WPP (2021)
- Amec Foster Wheeler (2021)
- Barclays (2019)
- Rolls Royce (2017)
- GlaxoSmithKline (2016)
- AstraZeneca (2016)
- BHP Billiton (2015)
- Smith & Nephew (2012)
The question is why?
Why – with the U.K. having its own FCPA-like law – is the U.S. still bringing FCPA enforcement actions against U.K. companies?
