Legal 500 Leading Firm 2026Â Â /Â The Time Best Law Firms 2026Â /Â 40+ Years of Expert Legal Practice in London
Recognised as a Legal 500 Leading Firm 2026 and included in The Times Best Law Firms 2026, with more than 40 years of expert legal practice in London, our solicitors advise companies, directors and senior executives on bribery and corruption compliance, investigations and prosecutions.
If you have been approached by the Serious Fraud Office (SFO), suspect corruption within your organisation or are weighing a self-report, call our solicitors on +44 20 7387 2032 or complete our online enquiry form for confidential advice. We act for clients across London and throughout England and Wales.
Call +44 20 7387 2032 Make a Confidential EnquiryThe Bribery Act 2010 has been in force since 1 July 2011. It placed the UK at the forefront of anti-corruption legislation and imposes severe penalties, including unlimited fines, up to ten years' imprisonment for individuals and exclusion from public procurement for convicted organisations.
Our bribery and corruption specialists have vast experience in this field. We work closely with companies on compliance with the law, and we represent both organisations and executives facing investigation into allegations of corrupt practices or wanting to self-report an incident to the SFO.
Our credentials include:
Recognised as a Legal 500 Leading Firm 2026
Included in The Times Best Law Firms 2026
More than 40 years of expert legal practice in London
Partner-led representation in SFO investigations and prosecutions
Advice on compliance, self-reporting and Deferred Prosecution Agreements
Close collaboration with leading King's Counsel and forensic accountants
The Bribery Act 2010 modernised the criminal law on offering or receiving bribes. It is a particularly stringent piece of legislation and introduced a strict liability offence, specific to companies and other commercial organisations, of failing to prevent bribery. This places a burden on companies to prove they have adequate anti-bribery procedures and policies in place if they are to avoid prosecution and heavy penalties.
The Act has a very wide reach. Any person, whether or not a UK national, can be prosecuted if an act or omission forming part of a bribery offence takes place in the UK, or where they have a close connection with the UK. The Act applies to any business or commercial organisation regardless of size, and the company does not have to be incorporated in the UK. If it carries on a business, or part of a business, in the UK, it falls within the scope of the Act.
Bribery is the giving of a financial or other advantage in connection with the improper performance of a relevant function or activity. It is not limited to cash payments; it can include material gifts or favourable treatment.
The functions and activities to which the offences apply are widely defined. Almost any situation connected to the public, business and professional sectors is covered, whether or not it takes place in the UK, provided it meets one or more of these conditions:
The function or activity is expected to be performed in good faith
The function or activity is expected to be performed impartially
The person performing it is in a position of trust by virtue of performing it
The Bribery Act sets out two general offences and two further offences directed at commercial bribery:
The giving, promising or offering of a bribe.
Agreeing to receive, or accepting, a bribe.
This offence does not require the official to carry out their functions improperly, only that they have been improperly influenced.
A strict liability offence committed by a commercial organisation that fails to prevent bribery, whether or not it is culpable.
A particularly demanding aspect of the Bribery Act, distinguishing it from other forms of corporate fraud law, is the positive obligation it imposes on companies to have anti-corruption procedures in place.
The offence of failing to prevent bribery is automatically committed by a commercial organisation if someone associated with it, such as an employee, agent or subsidiary, commits a bribery offence. It is irrelevant whether the organisation was aware of the unlawful conduct. It faces significant fines unless it can show that it had adequate procedures in place.
This is not an area any company can ignore. Surveys of UK businesses have repeatedly found that a substantial proportion have never conducted an anti-bribery and corruption risk assessment, and many report operating in markets where corrupt payments are treated as a normal part of doing business. It is no defence that bribery is a usual or necessary trading practice, and the investigating and prosecuting authorities treat these offences with the utmost seriousness.
The government has set out six guiding principles to help companies assess whether their procedures would stand up as adequate:
Measures proportionate to the bribery risks the business faces and the nature, scale and complexity of its activities.
Directors and owners committing to prevent bribery and building a culture of zero tolerance.
Periodic, informed and documented assessments of internal and external bribery risks.
Checks on agents, intermediaries and other associated persons.
Anti-bribery policies communicated and trained throughout the organisation.
Procedures kept under regular review and updated as risks change.
For advice on whether your policies and procedures are sufficient to avoid criminal liability, please contact us.
The strong wording of the Bribery Act, coupled with government guidance, has left ambiguities, particularly around facilitation payments and corporate hospitality. Genuine hospitality that is reasonable, proportionate and given in good faith is not prohibited, but the boundary with an unlawful advantage is fact-sensitive, and facilitation payments remain illegal under UK law even where they are commonplace abroad.
Companies need clear policies and records. Our bribery and corruption solicitors are ready to offer the advice needed to interpret and comply with the law.
The SFO is the lead agency for investigating serious bribery. Corruption indicators, such as unexplained preferences during tendering periods, private meetings with decision-makers or abnormal payments, can trigger an investigation and, where appropriate, prosecution.
Companies that discover misconduct face a strategic decision on self-reporting, which can open the door to a Deferred Prosecution Agreement rather than conviction. The handling of the internal investigation, privilege and disclosure will shape that outcome.
Early advice protects privilege and keeps every option open, including self-reporting.
Suspend routine document destruction and secure emails, payment records, contracts and devices.
Establish the facts under legal privilege before decisions on reporting or discipline are made.
Timing and content are critical, and a well-judged report can support a Deferred Prosecution Agreement.
The interests of the company and of implicated executives will often diverge, and each needs independent advice.
Demonstrable improvement to compliance can mitigate penalties and support the adequate procedures defence in future.
Depending on the nature of your matter, your case may be handled by Jeffrey Lewis, Siobhain Egan or Keith Wood, each of whom has substantial experience of SFO engagement, corporate compliance and complex financial crime defence. Jeffrey Lewis worked in the City as an investment analyst before qualifying as a solicitor, experience that informs the firm's practical advice to boards.
Individuals face up to ten years' imprisonment and unlimited fines. Companies face unlimited fines and exclusion from public contracts.
Yes. Failing to prevent bribery is a strict liability offence, and the company's only defence is proving it had adequate procedures.
Yes. It reaches conduct worldwide where the person or business has a close connection with the UK or carries on business here.
No. Facilitation payments are illegal under the Bribery Act, even in countries where they are a common business practice.
Possibly. A well-timed self-report can support a Deferred Prosecution Agreement, but take specialist advice before approaching the SFO.
If you have been approached by the SFO, suspect an incident of corruption within your organisation or need your compliance procedures reviewed, early specialist advice protects the business and the individuals within it. Lewis Nedas Law is recognised as a Legal 500 Leading Firm 2026 and included in The Times Best Law Firms 2026, with more than 40 years of expert legal practice in London.
To speak with a member of our specialist team, call +44 20 7387 2032 or complete our online enquiry form to arrange a confidential consultation.
Call +44 20 7387 2032 Arrange a Confidential Consultation