Sections 1 and 2 of the Bribery Act prohibit the offer and receipt of a bribe by any person.  Unlike the FCPA, this covers both private and public sector bribery.

Section 6, in comparison, applies only to foreign public officials.  A foreign public official:

  • holds a legislative, administrative or judicial position, whether appointed or elected, in a country outside the UK;
  • exercises a public function for or on behalf of a country outside the UK or a public agency or enterprise of that country; or
  • is an official or agent of a public international organization.

According to the Ministry of Justice Guidance, foreign public officials include “professionals working for public health agencies and officers exercising public functions in state-owned enterprises.  [Foreign public officials can also be an officials or agents of a] public international organization, such as the UN or World Bank.”


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