Bribery & Corruption

A renowned set with a well-deserved reputation in business crime, our deep bench of very talented barristers have a formidable track record for handling major bribery and corruption.


In the past few years, there has been a significant change in the way in which prosecuting authorities have dealt with allegations of commercial crime.  These changes have coincided with an increase in charges brought by the SFO and the FCA, and have included: the availability of ‘blockbuster’ funding for the SFO to “take on very big cases”; the introduction of Deferred Prosecution Agreements for corporates; encouragement of self-reporting and whistle-blowing; offering immunity from prosecution in return for giving evidence; formalised plea bargaining arrangements; and global settlements to ensure international resolution.

The Bribery Act 2010 has added to the prosecutorial armoury.  It abolished the UK’s entire framework of anti-corruption legislation and economically replaced it with a modern and comprehensive law identifying particular offences of paying (or offering) a bribe, accepting a bribe or bribing a foreign public official, with a maximum sentence of 10 years’ imprisonment.

Controversially, the Act extended the liability of a corporation and rendered a corporate entity guilty if anyone acting on its behalf bribes another anywhere in the world.  This has radically overhauled the law on corporate liability and extended the jurisdiction of the UK courts.  Although the offence is one of strict liability, there is a defence for the commercial organisation to show it had adequate procedures in place to prevent persons associated with it from committing bribery offences.

QEB Hollis Whiteman has been at the forefront of these changes and the cases arising from them.

Our Experience

As established leaders in this field, QEB Hollis Whiteman has considerable experience in advising, prosecuting and defending in the most high-profile domestic and foreign bribery and corruption cases. Members of Chambers were instructed in the first two deferred prosecution agreements entered into in the UK and act, both defending and prosecuting, in many of the largest cases conducted by the Serious Fraud Office, including Rolls Royce. In addition, Head of Chambers, Mark Ellison QC was instructed by the Home Secretary to carry out an independent review of undercover policing and possible police corruption connected to the Stephen Lawrence case.

Chambers and its members are consistently ranked as leaders in this field by the profession's legal directories. We provide expert strategic advice at every stage of an investigation and prosecution, including on best compliance, remedial action and whether to self-report or not. Acutely aware of the potential reputational damage to professionals and companies that allegations of bribery and corruption can have, we work closely with our professional clients to ensure that cases are handled with the utmost sensitivity.

Members of Chambers have also been called upon to comment on the advent of new legislation, providing a contributing author to two leading practitioners’ texts, ‘Bribery; Law and Practice’ and ‘the Blackstone’s Guide to the Bribery Act 2010’, published by the Oxford University Press. We are truly leaders in the field.

Notable Cases

Airbus Group: SFO investigation into allegations of fraud, bribery and corruption

Balfour Beatty: First Civil Recovery Order imposed by the SFO

Anthony Bogdin: Local authority corruption

Bruce Hall: Corruption offences worth $40million

Cash for Honours: Acting for a central figure  in the 'Cash for Honours' investigation

GlaxoSmithKline: SFO investigation into GlaxoSmithKline plc and its subsidiaries

Innospec: Landmark ‘global corporate settlement’ case involving overseas corruption

Mabey & Johnson: SFO Prosecution leading to first ever ‘Serious Fraud Plea Agreement’

Millennium Dome corruption case: Defending a lighting expert

MOL: Representing Hungarian energy group in arbitration relating to claims of bribery by Croatia’s former prime minister.

Rolls Royce: SFO investigation into allegations of bribery and corruption

Securency: SFO prosecution for making corrupt payments to a foreign official

Smith and Ouzman: Acquittal in SFO prosecution for alleged corruption offences involving nearly half a million pounds.

Standard Bank: Landmark case culminating in the UK’s first DPA and use of s7 Bribery Act 2010

Stephen Lawrence: Independent review of undercover policing by Mark Ellison QC instructed by the Home Secretary

Swift Oil: Acquittal of three former executives of an international group of companies on corruption charges involving Nigerian government officials

Tobiasen: the first ever prosecution for overseas bribery

XYZ Ltd: Second Deferred Prosecution Agreement in England and Wales

Recent Cases

SFO v Barclays PLC & Or's (2018)

Ben FitzGerald acts for Barclays and Barclays Bank in the SFO’s prosecution concerning the...

FCA v A Global Bank (2018)

Lucy Kennedy is currently providing direction to an FCA team, they are presently conducting a...

Bermingham (2018)

Philip is instructed (led by Clare Sibson QC) to defend a former Barclay’s Bank rate...

R v B (2017 - 2018)

Peter Finnigan QC leading Lucy Kennedy are currently instructed to represent the former CEO...

Z (2017)

Advising senior staff facing investigation into allegation of conspiracy to defraud and bribery...


Charges dismissed in Barclays fraud case

Crispin Aylett QC and Ben FitzGerald acted for Barclays PLC and Barclays Bank PLC, together with...

EURIBOR Trial Commences

Sean Larkin QC and Philip McGhee are representing defendants in the EURIBOR...

FCA abandons insider dealing investigation

Jason Mansell acted for a senior employee of a PLC who on multiple occasions and in breach of...


Consent of the principal: effect under the Bribery Act 2010

Katherine Buckle studies the decision ruled by the Court of Appeal on whether the prosecution, in bringing a case under section 1 of the Prevention of Corruption Act 1996, must prove that a principal consented to their agent giving or receiving a bribe.

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Adequate Procedures Handout - Bribery Act 2010

Sean Larkin QC and Rachna Gokani provide further guidance in relation to the Bribery Act.