Sullivan & Cromwell's Juan Rodriguez and Louise Delahunty warn the Bribery Act and competition law could prove a lethal combination for companies with poor compliance

After the lengthy gestation and July roll-out of the Bribery Act, UK and global companies are dealing responsibly with its challenges. Companies have spent considerable time and money on ensuring that they have good compliance systems and a compliance culture.

But no-one can rest on their laurels. Criminal behaviour, as well as behaviour that exposes companies to high fines and reputational damage, takes many forms and will not necessarily be extinguished because one risk box is ticked. Now is the time for responsible corporates to take a holistic view. Your Bribery Act – and Foreign Corrupt Practices Act (FCPA) – policy is in place, your senior management has endorsed your approach, your staff are trained and relevant contractual documents amended. But have you addressed all the risks?