Category Archives: UK Bribery Act

The New ‘Failure to Prevent Fraud’ Corporate Offence — UK Government Publishes Guidance

by Karolos Seeger, Aisling Cowell, Andrew H. Lee, and Sophie Michalski

Photo of the authors

Left to Right: Karolos Seeger, Aisling Cowell, Andrew H. Lee, and Sophie Michalski (photos courtesy of Debevoise & Plimpton LLP)

On 6 November 2024, the Home Office finally published government guidance on the corporate offence of failure to prevent fraud (the “FTPF Offence”), which was introduced in the Economic Crime and Corporate Transparency Act 2023 enacted last October. The new offence will now come into force on 1 September 2025, giving companies a longer period to prepare than had been expected. 

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Former Aide to Madagascan President Sentenced for Soliciting Bribes Under UK Bribery Act

by Pamela Reddy, Robin Spedding, and Matthew Unsworth

Photos of the authors

Left to Right: Pamela Reddy, Robin Spedding, and Matthew Unsworth (photos courtesy of Latham & Watkins LLP)

Sentencing of Romy Andrianarisoa, the first ever foreign public official to be convicted under the UK Bribery Act of 2010, provides important takeaways.

On 10 May 2024, Romy Andrianarisoa was sentenced to three and a half years’ imprisonment for soliciting bribes contrary to Section 2 of the Bribery Act 2010 (Bribery Act). Andrianarisoa, former Chief of Staff to President Andry Rajoelina of Madagascar, requested substantial cash payments in exchange for helping UK-headquartered Gemfields Group Ltd (Gemfields) secure mining rights in the country. Her associate, French national Philippe Tabuteau, was also handed a 27-month sentence for his role in the scheme.

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