Almost three years after the Bribery Act 2010 came into force, a new weapon for UK prosecutors, enshrined in the Crime and Courts Act 2013, came into effect on 24 February 2014, whereby the Serious Fraud Office and the Director of Public Prosecutions picked up the carrot of Deferred Prosecution Agreements (DPA) to add to the stick of the Bribery Act.
DPAs in the US federal system have been used by the Department of Justice in criminal prosecutions and the Securities and Exchange Commission in securities enforcement actions for over 20 years, and this inherently US approach has proved, to a large extent, successful.