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Bribery Act 2010 definition and meaning | AML glossary

What is the Bribery Act 2010? Definition and AML compliance meaning.

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The Bribery Act 2010 definition: What it means in AML compliance.

The Bribery Act 2010 is the UK’s primary legislation for tackling bribery and corruption. It sets out clear offences covering both individuals and organisations, making it one of the strictest anti-bribery laws globally. Businesses operating in the UK or with links to the UK can be held accountable for bribery, no matter where it takes place. This means that even if an offence is committed overseas, companies can still be prosecuted under UK law.

The Act defines four key offences. The first is offering, promising, or giving a bribe – an attempt to induce someone to act improperly. The second is requesting, agreeing to receive, or accepting a bribe. The third is bribery of a foreign public official, where anything of value is offered to gain a business advantage. The final offence applies to businesses and is known as the “failure to prevent” offence. If a company fails to stop bribery within its organisation or supply chain, it can be prosecuted unless it can demonstrate that it had adequate procedures in place to prevent it.

Penalties for breaches are severe. Individuals found guilty can face up to ten years in prison, unlimited fines, and disqualification from serving as a director. Companies can also be fined without limit, and convictions can lead to reputational damage and loss of business opportunities. These consequences make it clear that taking bribery seriously can protect your business from financial and legal risks.

The Act places significant responsibility on businesses to put in place strong anti-bribery and corruption (ABC) policies. This includes carrying out risk assessments, training employees, and keeping detailed records of gifts, hospitality, and payments to third parties. Companies must show that they are actively working to prevent bribery rather than just having policies on paper.

Bribery Act 2010 meaning

“The Act reflects the UK’s continued commitment to combat bribery and provides a modern, comprehensive scheme of bribery offences. The Act covers all forms of bribery but there is a clear focus on commercial bribery, evidenced by the fact that two of its four offences are business related.”

Crown Prosecution Service (CPS)

Bribery Act 2010: Joint Prosecution Guidance of The Director of the Serious Fraud Office and The Director of Public Prosecutions

What role does the Bribery Act 2010 play in AML compliance?

For AML compliance professionals, the Bribery Act 2010 is closely tied to efforts to stop financial crime. Bribery and corruption are often linked to money laundering, with illicit payments being disguised through complex transactions, offshore accounts, or shell companies. If bribery takes place, there’s a strong chance that money laundering is happening alongside it.

One of the biggest challenges is identifying bribery within financial transactions. Payments may be hidden under vague invoice descriptions, routed through intermediaries, or justified as consultancy fees. AML teams need to pay close attention to high-risk jurisdictions, politically exposed persons (PEPs), and industries with a history of corruption. Enhanced due diligence (EDD) is essential when working with third parties, particularly where financial incentives could influence decision-making.

Another key consideration is corporate liability. Under the Bribery Act, businesses are expected to have adequate procedures to prevent bribery. This overlaps with AML obligations, which require firms to assess financial crime risks and implement controls to mitigate them. Strong internal policies, whistleblowing mechanisms, and staff training help create a culture where bribery and financial crime are identified and stopped early.

Failing to act on bribery risks can have serious consequences. If a company is caught up in a bribery scandal, regulators will ask what steps were taken to detect and prevent it. If money linked to bribery has been moved through the financial system, AML teams will be expected to explain why it wasn’t flagged as suspicious. This is why having a joined-up approach across compliance, legal, and risk management functions is essential.

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