UK Bribery Act 2010 — §7 Failure to Prevent + Adequate Procedures
UK Bribery Act 2010 §1, §2, §6, §7 + MoJ 6 Principles + SFO Corporate Co-operation Guidance · best for UK subsidiary · UK contract · UK director
Companies with FCPA/UKBA/Sapin II/NACC nexus start with UK Bribery Act 2010 — §7 Failure to Prevent + Adequate Procedures — NYC Legal fields a full Anti-Corruption & Investigations Bar.
Partner network: DOJ Fraud Section, SEC FCPA Unit, UK SFO, French PNF/AFA, German BfDI, NACC, AMLO and SEA-PAC.
UK Bribery Act 2010 — §7 Failure to Prevent + Adequate Procedures takes 90-270 working days at 685,000-2,485,000 บาท — includes risk assessment, policy, training, due diligence, monitoring and certification.
We liaise with DOJ Fraud Section, SEC FCPA Unit, UK SFO, French AFA/PNF, German BfDI, NACC, AMLO and ISO-accredited certification bodies.
Coverage: FCPA 1977, UKBA 2010, Sapin II 2016, Thai NACC 2018 §123/5, EU Whistleblower 2019/1937, ISO 37001/37002, AMLA, OECD and UNCAC.
ISO 37001 — certified 95+ firms (BOI, SET-listed, government contractor) with zero recertification rejection.
Coverage
How it works
- 1
Risk assessment (14 days)
Bribery risk map + geographic + sector + transaction + third-party risk + control gap analysis.
- 2
Policy + procedures
ABC policy + gift/hospitality + facilitation payment + sponsorship + conflict of interest + whistleblower.
- 3
Training + communication
Top-down commitment + role-based training + e-learning + attestation + multi-language.
- 4
Third-party DD + monitoring
Red-flag screen + sanctions/PEP + adverse media + on-site visit + ABC clauses + ongoing monitoring.
- 5
Audit + ISO 37001 certification
Internal audit + management review + Stage 1+2 audit + 3-year cycle + surveillance.
Frequently asked questions
Who needs UK Bribery Act 2010 — §7 Failure to Prevent + Adequate Procedures?
UK subsidiary, UK contract, UK director, Commonwealth nexus and any firm with FCPA/UKBA/Sapin II/NACC nexus.
Total cost?
685,000-2,485,000 บาท — includes risk assessment, policy, training, DD, monitoring, certification and legal opinion.
Timeline?
90-270 working days — ABC 90-240, FCPA investigation 120-540, ISO 37001 120-270, Whistleblower 60-150.
FCPA vs UKBA vs Sapin II?
FCPA = foreign officials only. UKBA = commercial + foreign + §7 failure-to-prevent. Sapin II = 8 pillars + AFA audit + CJIP.
Who does NACC §123/5 cover?
Legal entities whose directors/employees bribe — 8 Adequate Measures defense + fines up to 2× benefit.
Does EU Whistleblower Directive apply to Thai firms?
Yes if you have an EU subsidiary/branch with ≥50 employees — internal channel + 7-day ack + 3-month feedback + GDPR + retaliation reverse burden.
ISO 37001 ABMS cost?
Gap analysis + design 485K-1.485M THB + Stage 1+2 audit 285K-685K THB + 185K/year surveillance + 3-year recertification.
DOJ Corporate Enforcement Policy 2023?
Voluntary self-disclosure + full cooperation + timely remediation = presumption of declination (no prosecution) + 50-75% fine reduction.