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How can corporates manage bribery risk as they fight to survive COVID-19

As the lockdown persists and businesses become more desperate, Fiona Horlick QC and Jeremy Scott-Joynt look at why this could mean more corporate bribery and corruption.

With spare bedrooms or kitchen table corners continuing to do double duty as office space, many businesses – particularly those whose trade has shrunk – will be aching for a return to normality.

However, normal may not return for a long time. Supply chains may shorten. Working practices may change. Long-settled business relationships may be sundered as partners may have ceased to trade. Battered businesses will be desperate for new deals as they seek to keep their staff working.

In other words, it’s a perfect time to bribe someone – and the ultimate test of whether a business’s anti-bribery programme will prevent it, or fail to do so.

In the Business Crime team’s latest article, Fiona Horlick QC and Jeremy Scott-Joynt look at these risks in more detail.

Don’t fail to prevent: how corporates can avoid missing bribery risk as they fight to survive the COVID-19 contraction.

The article covers:

  • Why the post-lockdown period could mean more bribery and corruption?
  • The law on failing to prevent
  • How might bribery come about?
  • Why should an organisation be concerned?
  • What can be done?

About the authors

Fiona Horlick QC’s experience of financial crime, regulation and enforcement is wide ranging, covering:

  • Large scale MTIC fraud
  • International advance fee fraud
  • Tax fraud
  • Fraudulent trading
  • Mortgage fraud
  • Money laundering and asset recovery
  • Bribery and corruption

Fiona is the co-editor and major contributing author of the leading work on the Bribery Act 2010 Lissack and Horlick on Bribery published internationally by LexisNexis. The 3rd edition will be available in Autumn 2020. This renowned publication provides a comprehensive and detailed overview of bribery in both a national and international context.

Jeremy Scott -Joynt came to the Bar after a successful career in banking and regulation, having occupied senior compliance roles in two international banks. Jeremy also spent four years at the Financial Services Authority as an intelligence and investigations specialist, running fraud and corruption enquiries and latterly serving as Deputy MLRO.

His practice has a particular focus on business crime and regulation. He has assisted clients in their dealings with the Financial Conduct Authority, the Serious Fraud Office, the Gambling Commission, the Maritime and Coastguard Agency, the Environment Agency and the Health and Safety Executive.  He has also been seconded to the FCA.

Find Out More

Read the full guidance note here: Outer Temple Chambers_Failure to Prevent Bribery Guidance Note

If you would like to discuss any of the issues covered in this article please contact Fiona Horlick QC or Jeremy Scott-Joynt directly or via their practice management team; David Smith on +44 (0)20 7427 4905 or Colin Bunyan on +44 (0)20 7427 4866 who would be happy to have a discussion in the strictest of confidence.

Covid-19, Business Crime, Business Crime during Covid-19, News 24 Apr, 2020


Fiona Horlick KC

Call: 1992 Silk: 2019

Jeremy Scott-Joynt

Call: 2018

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