It’s a been a few days since the UK’s Bribery Act became effective, making some questionable corporate behavior become clearly illegal. There have been thousands of news stories, legal alerts, and dire warnings about the line in the sand drawn on its date of effectiveness, July 1.
Now, there is a bit a waiting, a calm before the storm, until we hear the first government action. Companies with a UK presence have most likely taken a look at their operations and implemented the changes needed to comply with the new law. (Perhaps that is optimistic.) The SFO now has a loaded gun and is likely on the hunt for behavior that violates the new law.
It took decades before the FCPA became actively enforced. I don’t expect it will take as long to see the first action under the Bribery Act. The SFO has already seen how effective FCPA has been in the United States. (If you consider “effective” to be good headlines and relatively easy wins.)
When will the first action happen? Will it be a government investigation or self-reporting? What industry will be first?