Susannah Cogman and Jeremy Sher recently published an article in the monthly newsletter of the British-Argentinian Chamber of Commerce on the application of the Bribery Act to Argentinian firms. The article discusses the extra-territorial effects of the Bribery Act, and current enforcement trends. Susannah and Jeremy observe that:
Non-UK businesses are increasingly taking steps to ensure that that they have adequate procedures to comply with the Bribery Act. This is because the new ‘corporate offence’ represents a significant extension of corporate liability for bribery and corruption, and an ‘adequate’ compliance programme may provide a defence.