UK Finance has published this guidance saying that the ambiguity in interpretation adds costs and delay to corporate anti-bribery and corruption efforts and can reduce appetite for doing business with new markets.  Varied interpretations in company policies can also hold back collective action and collaborative work, adding complexity to efforts to share risk intelligence on official corruption and to support public integrity initiatives.  It says that it has therefore worked with its members to develop a practical and risk-based definition of public officials for the purposes of anti-bribery and corruption compliance.  The resulting guidance sets out the technical approach and recommended guidance to help industry work to a consistent definition.  UK Finance says that it recognises that each firm will need to apply its own risk appetite, but the guidance proposes a broad approach building on both international legal analysis and recent case law, including on borderline cases such as public contractors and state-owned enterprises.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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