Domestic corruption has moved up on the UK’s enforcement agenda with the launch of the government’s anti-corruption strategy in December 2025.
The strategy committed £15 million of additional funding to expand the City of London Police’s Domestic Corruption Unit (DCU), a specialist team established in 2024 which investigates corruption, bribery and abuse of position offences across England and Wales within public sector organisations. By January this year, six people had been arrested as part of an investigation into the alleged fraudulent allocation of hundreds of homes owned by Barking and Dagenham Council’s housing company, B&D Reside. The DCU also made three arrests of senior figures connected to the Police Federation of England and Wales on suspicion of fraud by abuse of position.
While these developments highlight the increasing focus on corruption and abuse of trust within public institutions, the issue is not confined to the public sector. Organisations both public and private should understand the law around bribery in order to protect their employees, reputation and businesses.
What is domestic bribery?
Under the Bribery Act 2010, domestic bribery occurs when someone offers, promises, gives, requests or accepts a financial or other advantage in exchange for the improper performance of a relevant function or activity within the UK.
There is a separate offence of bribing a foreign public official within the Act, which is subject to different provisions.
Does bribery only apply to public officials?
No.
Many people assume bribery laws only apply to government officials. However, the Bribery Act 2010 also covers commercial relationships. For example, paying a procurement manager at another company to favour your bid over a competitor’s could amount to bribery.
Can a gift be considered a bribe?
Potentially, yes.
A gift does not need to be cash to amount to a bribe. Hospitality, travel, entertainment, discounts and other benefits could all raise concerns if they are intended to influence someone’s decision-making or reward improper conduct.
However, the Bribery Act is not intended to criminalise ordinary business hospitality. Reasonable and proportionate gifts or entertainment provided for legitimate business purposes are unlikely to amount to bribery.
Whether a gift crosses the line into criminal behaviour will always depend on the circumstances – such as its value, timing and purpose. A modest Christmas hamper for a longstanding client is very different from an expensive watch for someone deciding a public procurement exercise.
Does a bribe have to be accepted for an offence to be committed?
No.
An offence can be committed by offering or promising a bribe, even if the recipient rejects it and no money changes hands.
Can someone be prosecuted for accepting a bribe?
Yes.
The law applies to both sides of the transaction. Offering a bribe and accepting a bribe are separate criminal offences.
Can my company be liable for an employee’s actions?
Potentially.
A company may be prosecuted if an employee, agent or other associated person commits bribery on its behalf. Businesses can also face liability for failing to prevent bribery unless they can demonstrate that they had adequate anti-bribery procedures in place, such as in the 2018 Skansen Interiors Limited case. These might include a written bribery policy, staff training, due diligence on third parties and effective reporting procedures.
Who investigates and prosecutes bribery offences?
Major bribery cases are typically investigated and prosecuted by the Serious Fraud Office. Others may be investigated by local police forces or specialist units such as the City of London Police’s Domestic Corruption Unit, with prosecutions brought by the Crown Prosecution Service.
Are facilitation payments legal in the UK?
No.
Facilitation payments, sometimes known as “grease” payments, are small unofficial payments made to speed up or secure routine actions, such as processing permits or clearing goods through customs. Unlike some countries, the UK treats facilitation payments as bribes. Even relatively small payments intended to obtain preferential treatment can amount to bribery under the Bribery Act 2010.
What are the penalties for bribery?
Bribery offences carry severe consequences. Individuals can face up to 10 years’ imprisonment, unlimited fines and confiscation of criminal assets. In November 2025, former MEP Nathan Gill was jailed for over 10 years after admitting he took bribes for making pro-Russian statements and other activities in the European Parliament on behalf of a pro-Russian Ukrainian politician.
Companies may receive unlimited fines and can also be excluded from bidding for public sector contracts. In May 2026 Ultra Electronics Holdings Limited agreed a Deferred Prosecution Agreement with the Serious Fraud Office after accepting responsibility for failing to prevent bribery. The company agreed to pay almost £15 million in penalties and costs and implement compliance reporting, although no individual was jailed in that case.
What should I do if I am investigated for bribery?
Specialist legal advice should be sought as early as possible as this can help protect your position during interviews under caution, searches, document requests, and any subsequent criminal investigation.
How can Lewis Nedas help?
Lewis Nedas Solicitors advises individuals and businesses facing allegations of bribery and corruption. The firm also assists organisations with internal investigations, compliance issues and self-reporting to the Serious Fraud Office where appropriate.
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