The Bribery Act: beyond adequate?

• The House of Lords’ review of the Bribery Act 2010 makes two particularly important interventions: the first relates to interpretation of the notorious ‘adequate procedures’ test; the second is a strong push for government to reform ‘white collar’ criminal law so that vicarious liability applies to a far wider range of offences.

The Bribery Act 2010 (BA 2010) is one of the more acclaimed pieces of legislation of recent years. It has been the subject of numerous superlatives: ‘the toughest anti-corruption legislation in the world’, ‘the gold standard’ and so on. In 2018 the House of Lords constituted a Select Committee, chaired by Lord Saville, to consider its effects (see also Lord Saville's NLJ article, 'Bribery in the spotlight'). After a lengthy process of taking evidence from a wide variety of interested parties, the committee issued its report on 14 March 2019 (The Bribery Act 2010: post-legislative scrutiny,