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Topic 3

Foreign Corruption and Multinationals: UK and the European Problems and Challenges

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With an increase in globalization and interconnectedness of the world, multinational

companies are increasingly playing a major role in the development and contribution of a global

economy. The establishment and practices of these companies have also introduces various acts

that limit manipulation, corruption, exploitation, bribery and other illegal activities that they can

employ to gain a competitive advantage within the foreign economy. Such acts have impacted the

way multinationals carry out their operations, being more cognizant of prosecution, fines and other

penalties. Within the Western sphere, the United Kingdom and Europe have particularly taken

many actions to limit such illegal practices and try to embark on an ethical path of business

operations and relations. Such measures have not just been implemented on domestically operating

firms, but also to multinationals which are increasingly playing a part in constructing to the

European economy. Governments within Europe take pride in the fact that such practices are not

needed for businesses to flourish in the region, since businesses are provided with equal

opportunities including multinational companies. The United Kingdom Bribery Act is the basis of

ethical practices as it limits and punishes such offenses committed either by its companies on

domestic soil, or by its companies on foreign land. The United Kingdom Anti-Corruption Act does

not only establish punishments for multinational businesses involved in this field, but also makes

sure that company are employing preemptive policies to regulate any form of corruption by

punishing them for even corruption caused by any of the company representatives1.

The main purpose of this essay will be to evaluate the problems and challenges faced by

Europe and the United Kingdom with regards to foreign corruption and multinational companies

and how the application of certain regulatory Acts limit these issues. It will be divided into five

1
Chris Scheltinga, 'United Kingdom Corruption Report' (Business Anti-Corruption Portal, 2018)
<https://www.business-anti-corruption.com/country-profiles/united-kingdom/> accessed 1 May 2018.
 Page 3

parts. The first part will begin by highlighting some of the major problems that are faced by Europe

and the United Kingdom with regards to effective implementation of anti-corruption legislations

and acts upon foreign multinationals. In the second part of the essay, I will mention the hurdles

and challenges that are faced by Europe in mitigating the effects of corruption that are caused by

multinationals. The third part will focus on structural problems and challenges will be looked in

the light of a case study approach of multinational companies in Europe and the United Kingdom

being charged with cases involving foreign corruption. In the fourth part, some policy

recommendations and initiatives to curb such corrupt practices with regards to Europe and United

Kingdom will be explored mainly focusing on fixing these issues and eradicating hurdles. Lastly,

this essay will conclude by weighing up the argument provided and tracing patterns of feasibility

of the application of these laws to ensure eradication of unfair practices.

Before moving on to the arguments, it is very important to lay down the scope of the

problem regarding multinational foreign corruption faced in United Kingdom and Europe. With

the introduction and strict emphasis on anti-corruption laws, many multinational companies have

implemented them as part of their internal auditing and accountability measures. Even with this, it

is hardly clear of how such policies are implemented as part of a corporate culture, since these

departments are not only controlled by the same companies but also personnel in charge are on the

payroll of the same institutions which means that in most cases effective implementation and

checks on its enforcement might be compromised. Because anti-corruption and anti-bribery

policies are relatively a newer domain when it comes to business ethics, many institutions are still

in the development phase of these processes. A recent study by Economist Magazine in

collaboration with Control Risks concluded that even though most companies agree to develop

measures to combat corruption and bribery within their organizations, they are under-prepared to
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deal with or expose scandals internally. There are social costs associated with multinationals who

engage in foreign corruption practices. They include, but are not limited to limited capacity for

business growth since most of the revenues are being passed off as bribes, diversion of funds from

internal business programmes, frustration etc. Another survey conducted in the United Kingdom

by KPMG found the following results: 58% respondents believed that the Anti-Corruption Act

within the United Kingdom ignores the reality of the role played by bribery as an acceptable way

of doing business in many other countries, due to which it seemed an impractical way of ensuring

accountability. However, 80% of the overall respondents were in favor of the Anti-Corruption Act

as addressing the problem of corruption and trying to enforce measures to limit it, if not completely

eradicate it.

Part I: Problems facing effective implementation of anti-corruption legislations and acts on

foreign multinationals in Europe and United Kingdom

The facilitation of money laundering and corruption cases have been carried out by many

shell companies registered in the United Kingdom, despite the efforts of various watchdogs and

investigations to prevent such an abuse from occurring. According to Transparency International

“more than 750 instances where companies registered across Britain – nearly all of which consisted

of nothing more concrete than a mailbox – had been used as part of a complex layering process to

hide illegal or suspicious money passing through the international financial system”2.

The biggest problem that Europe and the United Kingdom has to face with regards to

corruption carried out by foreign multinationals is facilitation of criminal acts via secrecy

2
Cahal Milmo, 'Hundreds of UK Companies Used to Facilitate Foreign Corruption worth Up To £80Bn, Report'
(iNews, 2017) <https://inews.co.uk/news/uk/hundreds-uk-companies-used-facilitate-foreign-corruption-worth-80bn-
report/> accessed 1 May 2018.
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jurisdictions. Since the British government has been too focused on paying attention to expose the

use of off-shore secrecy jurisdictions that are offshore it has not paid much attention to the system

that is in place within its domestic territory, that of tax avoidance and criminal activities worth

billions of pounds. As many as 800 companies have been found until early 2018 which have

registered to addresses housing thousands of businesses simultaneously to engage in activities such

as money laundering, corruption, bribery and threats which involves an estimated 80 billion in

dealings. A quarter of these companies which have been exposed still remain active, as part of the

failure on part of the government and anti-corruption department to facilitate them to a deserved

conclusion. The problem behind all of this is that in Britain there is a poor system of scrutiny and

oversight of company formation process. Such processes usually take less than 15 minutes, can be

done online through company formation websites like First Formations and Rapid Formations for

as little as 12 Pounds. This unregulated process which is being facilitated via many private

channels reduces the investigation of what kind of people are forming a company, what kind of

company is being formed and what purpose will the company serve. These private facilitators have

no interest after a company is formed and payments are made, so any kinds of activities carried

out in the name of such companies is not overseen. This is not to say that all companies made by

such channels are illegitimate, but the point is that it facilitates a system where exploitation and

corruption is very hard to tackle and eliminate.

Another problem that these countries face due to multinationals engaged in foreign

corruption is proving and tracing such actions. Companies that are registered in Europe, such as

Shell, have been caught in corruption scandals and implicated on charges for illegal actions in

countries including Azerbaijan, Ukraine and 11 others. While there is a growing concern and

suspicions are raised by offshore platforms like Bermuda and Panama, British institutions are
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seldom willing to realize that the same activities including money laundering, illegal transfers,

unregulated payments and bribes are being carried out under their noses within their territory even

with the enactment of legal acts for prosecuting those caught in such situations. Europe and the

United Kingdom is home to industries, factories and businesses which are owned by dishonest

individuals who employ corrupt measures to hide their black money.

The third problem that is faced is ineffective checks on money laundering, bribes,

corruption and dishonesty. Britain allows the setup of Trust and Company Service Provider

(TCSP) which are foreign specialist companies in certain fields of expertise. The setup of these

companies through the TCSP process means that they not only can easily evade anti-money

laundering checks, but also do not have to go through any accuracy checks with regards to who

holds these companies, including information on their final or beneficial owners. If the government

even decided to check a few companies through Company House, the institution in Britain

responsible for gauging the authenticity and reliability of companies, annual data of up to four

million records are handled by just 6 individuals. After a lot of pressure and protests, Britain has

become the first country in Europe that has now started verifying details of owners and

beneficiaries of companies. However, in order for effective accountability, it still has a long way

to go to the point where the origin and transfer of money can be traced and linked to the activities

responsible of generating these amounts. To make such a change worthwhile, more loopholes need

to be discovered with enforcement of current legislations via promotion of better environment for

regulation agencies.

Fourthly, there is an absence of a fine line that is drawn between acts that are legally

permissible and unethical. Here an assessment of the United Kingdom Bribery Act that was

introduced in 2010 will be contrasted with the legal framework within the United Kingdom. This
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Act relates provisions of offences relating to bribery with any actions of connected purposes.

Analysts reckon that that Act is the bar of the highest standard when it comes to global anti-

corruption standards and lays down penalties of those prosecuted under this act in forms of

imprisonment, confiscation of property, limited to unlimited fine and disqualification of company

directors. These penalties are applicable to all companies and individuals who commit crimes

anywhere, as long as they have any links to the United Kingdom. However, there are some serious

concerns that have been raised with regards to the scope of this Act. Many people argue that such

a strict measure may harm the competitiveness that British industry, goods and services enjoy in

the international market. Moreover, section 6 of the United Kingdom Bribery Act has a loophole

where these multinationals can carry out actions which are legally permissible under the law but

at the same time classified as unethical. In the Scots Law Times, Anwar and Deeprose take a

similar line when they talk about the controversy surrounding areas such as facilitation payments

and corporate hospitality which might spark questions, but are "essentially a form of extortion on

the payer and permissible under international jurisdictions pertaining to the commercial world"3.

Part II: Hurdles and Challenges towards mitigating foreign corruption by multinationals

Even though numerous initiatives, regulations and acts have been passed in the United

Kingdom and Europe to try and limit multinationals engaged in foreign corruption, many hurdles

still remain towards achieving a corruption-free Europe. The major hurdle hindering the

embracement of this journey is that there is a lack of agreement as to what constitutes as foreign

corruption with regards to multinationals? The UK Anti-Corruption and Bribery Act also entails

that businesses within the United Kingdom will be liable for corrupt actions undertaken by their

3
Anwar, Aisha and Gavin Deeprose, "The Bribery Act 2010" (2010). Scots Law Times. Sweet & Maxwell. (23).
ISSN 0036-908X.
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partners in other countries. However in most cases, because there are a number of middle men

involved, businesses back in the United Kingdom have no way of tracing their supplier to the end.

In such cases, agreements and acts that might otherwise be classified as corrupt would be used and

applied in a different context here, impeding the process of prosecution on such basis.

One of the major challenges facing corruption carried out by multinational companies in

United Kingdom or Europe is that countries might not be willing to mitigate the effects of

international bribery due to the problem of collective action. Collective actions are situations

where the benefit of one party means the loss of another, i.e. when individual motives are fulfilled,

it leads to inefficiencies for group motivations. When it compares to the aspect of foreign

corruption by multinationals involving international bribery, if a major clamp down on such an

avenue will lead to loss of rule of law, negative economic growth or disincentives for future

businesses being established, then countries like the United Kingdom will have to weigh up all

these factors against application of Acts that prevent bribery and corruption. Here, the selfish

aspect of the country comes to play, if the existence of such an avenue is not leading to too much

harm then the implementation of such legislations will be lenient and minimal if the offense is

small enough to be ignored. In other times, the state if faced with the hurdle of administrative and

managerial problems. Tracking and pinpointing the origins of such illegal activities may not be so

easy given that the process of company establishment is widespread and decentralized.

The second hurdle that creates a hindrance to embark on a path of corruption and bribery

free practice is the interpretation of broad nexuses that exist in not just United Kingdom, but

Europe as a whole. Authorities within these jurisdictions are reluctant to establish electronic

communication and bank links in order to create a nexus between business proceedings, territories

and monitoring authorities. This is because businesses and business practices have been given
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immense privacy and leeway while disclosing their records, no operations and processes employed

have to be submitted, just final statements upon which audits are completed. The United Kingdom

government tried to do this with Magyar Telecom, by not only creating a concrete jurisdictional

activity monitoring system, but also overlooking draft agreements, payments, and verification of

service links. Employers, employees and communication partners were made aware of this so that

they can be cognizant of undertaking any illicit or illegal activity constitution as corruption or

bribe. However, such strict forms of monitoring and implementation of anti-corruption and anti-

bribe systems made actors that were involved disincentivized, and the company lost efficiency to

operate and had to close down. Secondly, there is no fine line that divides companies that are

prosecuted and those who are not. For example, when the TSKJ joint venture was caught by the

United Kingdom Justice Department on charges of aiding, conspiracy and abetting - even though

only one member on Bonny Islands was a company based in the United Kingdom, all members

that composed of this joint venture fell under the prosecuted jurisdiction of the United Kingdom

but were then let go free of any charge. This shows the precedence that non United Kingdom based

companies who are otherwise involved with multinational ventures in corruption will not be dealt

with under these Acts, even though clauses within them clearly state that partners linked would be

prosecuted in the same manner.

Thirdly, the European governments are also faced with the hurdles of the operations of

their companies in developing countries and the existence of corruption in those circumstances.

Countries with corrupt state institutions, bureaucracy and governments align themselves with

multinationals to become the face of exploitation and illicit activities. Adax Petroleum Company,

which operated through its headquarters in the United Kingdom. Was involves in fraud worth

billions of pounds over crude oil exploration with the Nigerian Government. The British
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government was unable to indict the owners and directors because there was never any

documentation retrieved of such practices. Not only was this petroleum company involved in

fraud, bribery and corruption but it also encouraged the Nigerian government to engage in a ‘race

to the bottom’ by lowering down its standards of labor and environmental laws so that Adax

Petroleum can increase its share of profits and in turn offer more privileges and benefits to those

in the government who were on its side. However, there are instances where multinational officers

bribe the government officials to win patronage and contracts but get investigated by the

authorities. “Kellogg, Brown and Root, a subsidiary of Halliburton is now being investigated in

both Nigeria and the United Kingdom over allegations that the company paid out $200 million in

bribes to win a contract for the construction of a Liquefied Gas Plant in Nigeria”4.

In a few cases, the carrying out of corruption or the payment of bribes involve corporate

executives directly operating from Europe and the United Kingdom. This may be due to the

credibility and power of the higher echelons of businesses involved, which makes the process

much graver. In such situations, the main objective of the involvement of executives is to establish

personal communication and patronage network so that this settlement can well be applied again

when needed. Here, it becomes easier for the government to tap into lines of communication to

prosecute involved individuals who are dispensing these dispositions. The main aim of these

companies is to expand their operation in these developing countries, exploit the labor, drive out

competition, establish beneficiary networks and increase profitability. If this goes unaccountable

within Europe and United Kingdom, not only is the reputation and trade practices of the country

questioned but also the country is held responsible for all the sufferings and loses that developing

4
Branislav Hock, 'Foreign Bribery Enforcement: Credibility And Clarity Problems' (Global Trade without
Corruption, 2016) <https://www.oecd.org/cleangovbiz/Integrity-Forum-16-Branislav-Hock.pdf> accessed 1 May
2018.
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country’s population has to face. It is also accused of facilitating infrastructures that lead to more

corruption in developing countries.

The last hurdle that the European or United Kingdom government might face is intentional

or unintentional favoritism towards multinational companies that might be involved in such

practices. Favoritism is a form of corruption that is extended by government representatives due a

few political factors including successful lobbying donations, pressure groups etc. The government

of the United Kingdom may exercise favoritism towards certain multinationals or its leaders

because they are being provided with favors. In such scenarios, regulatory bodies which are under

the government are less likely to pursue the cases of these companies. Rather, these companies

will be successful in garnering favors from the government and get leeway for exercising

corruption. The reason why bribes will not be used in its general sense is because other factors are

serving the exact same purposes that bribe do, however they are legally classifies under a separate

category.

Part III: Structural problems and challenges – a Case study approach of foreign corruption

in UK and Europe

In the wake of the 21st century, the magnitude and number of multinational corruption cases

in Europe and the United Kingdom that have been prosecuted by government authorities is

concerning. Some of these cases have garnered widespread media attention, while others have

been hush-hush, with enormous patronage and resources employed to make sure that their image

is not affected. This problem, however, adequately represents the tip of an iceberg: regulatory

bodies are so caught up focusing on exposing bribery of public officials that they are ineffective

in indicting these cases when they are caught, and at other times such forms of corruption and

financial fraud usually goes unreported. Advocacy groups in Britain and Europe have fought many
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unsuccessful battles, because companies usually plead guilty and agree to pay fines at the first

charge against them is discovered in order to prevent deployment of further investigation that

might expose other aspects of cases which might push them in trouble.

The third biggest case of multinational foreign corruption to be prosecuted was BAE in the

United Kingdom which was fined $450 million for criminal charges in 2010, which were to be

paid in both the United States and the United Kingdom. BAE systems are Europe’s largest private

military contractor and was charge of fraud, bribery and conspiracy in tampering with overseas

contracts and trade deals. After 8 long years of running investigation of the company’s activities,

the United Kingdom Justice Department concluded that the company had not only lied about

having internal programs that ensure the application of anti-corruption and anti-bribery laws, but

also that the company has concluded arms deals with Saudi Arab, Hungary, Czech Republic and

other countries going against international laws dealing with trade practices. The United States

government got the most out of these fines, as BAE was involved in meddling with networks to

outdo American military companies to win contracts of fighter planes and other such equipment.

The problems and challenges faced by United Kingdom in this case was a few fold. Firstly

the courts found out that in 2006, when the investigation began in Britain under Prime Minister

Tony Blair, investigations in BAE’s deals with Saudi Arabia were halted as “Saudi leaders

threatened to provide the British government with tips on terrorism”5. Secondly, the fines of $450

million, even though might sound great in isolation, was a figure of concern by the British Serious

Fraud Investigation Department as being ineffective. This means that because this proportion of

fines is unlikely to have a huge blow on the finances of BAE, it will put it behind them and redeploy

5
Christopher Clark, 'BAE Systems to Pay $450 Million to Settle Allegations of Bribery' (Nytimes.com, 2010)
<https://www.nytimes.com/2010/02/06/business/global/06bribe.html> accessed 29 April 2018.
 Page 13

illegal means and continue evading accountability. Thirdly, there might have been a lot more

problems and illegal avenues of dealings and corrupt practices being pursued by BAE systems,

and them pleading guilty means that the investigation will not be carried down further. This means

that governments lose out on foreign corruption being done by such multinationals. Fourthly,

exposing and fining the actions of BAE in United Kingdom does not mean that problematic

practices are hindered in setups of these multinationals in other countries. For example, in the

United States, BAE is the one of the Pentagon’s single largest contractors foe such equipment,

generating vast amounts of revenue. Even though the British Justice Department filed a criminal

petition against BAE’s American subsidiary to the United States Department of Justice, no

investigation was carried out because the company enjoyed privileges of state institutions. Lastly,

the establishment of middle men and offshore companies means that the identities of persons or

parties involved cannot be identified. In this case, a network of ‘marketing advisors’ were

employed and offshore companies were set up on British Virgin Islands with an involvement of

billions of dollars in contractual payments.

Part IV: Policy recommendations and initiatives to curb such corrupt practices

Tackling such problems of corruption will require dedicated efforts by Europe and the

United Kingdom in light of all the problems and challenges highlighted above. To address the

supply side of corruption in developing countries, international initiatives to criminalize bribery

and promotion of exploitative practices need to be put into effect on the bases of United Kingdom’s

Public Body Corrupt Act and Prevention of Corruption Acts. However it needs to be considered

that certain clauses within these Acts are unclear, outdated and lacking a clear purpose since they

exclude overseas subsidiaries and unincorporated institutions that might not be subject to the laws

of United Kingdom. This change can be inspired by the extraterritorial laws regarding corruption
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and bribery which are in place in the United States. While clarifying the laws and providing them

a clear guideline to implement, these clauses can also incorporate recommendations by the OECD

Convention on Combating Bribery and Related Activities. Even the 2010 Bribery Act that was

passed by the United Kingdom government can include consolidation of common law and

statutory offences pertaining to bribery, and this refined version can be adopted by other European

governments.

Secondly, within the United Kingdom and Europe, institutions that are formed for ensuring

transparency and promoting accountability need to be strengthened. For example, the Department

of Justice whose primary purpose if the enforcement of ant-bribery and anti-corruption laws from

the Acts needs to be better staffed, provided with adequate resources, given warrants to investigate

operating procedures and money channels and permanent injunctions for violations. Moreover, the

most important change that needs to be brought about is that once a multinational company pays

fines over an illegal act, then the investigation should be continued to expose further problematic

decisions and actions that have been undertaken in order to ensure that a system of new regulatory

web with such enforceable practices are imposed in order for fairness in the conduct of

multinational corporations. Such a system of regulation can also take into account negotiations

and disincentives which were highlighted in the OECD Report on Transnational Bribery and the

need to introduce regulatory measures for such multinational companies. “The main contribution

by the OECD has been in the area of fighting corruption in international business transactions

among OECD countries and five non-OECD countries. It is a legally binding document, the

implementation of which is systematically monitored. This convention has since become a

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powerful tool in controlling international bribery”6. Fighting against corruption and corrupt

practices has to be brought to the forefront of international policy agenda and bribes need to be

criminalized beyond the borders of the state where the multinational is operating. The 2005 United

Nations Convention Against Corruption can also serve as an instrument for the development of a

cohesive complex legal act for the regulation of corruption, by not only coming to an international

consensus on what accounts for criminalized corruption and what actions states can take to prevent

it but also for the development of international cooperation which will facilitate in extension of

prosecution under anti-corruption and anti-bribery act beyond the borders of United Kingdom and

Europe.

Thirdly, the aspect of favoritism via lobbying and beneficial treatment needs to be

eradicated. It should not be the case that companies that are making large donation or employing

former government officials are being poorly regulated or given a lot of leeway when it comes to

investigation and auditing. Neither should it be that companies are being provided with large

government contacts based on some pre-agreements that was settled in private. It should also be

made unethical and illegal for influential companies within the United Kingdom like KPMG to

send their staff to assist the Treasury in advice regarding Tax laws because they have selfish

interests of benefitting their corporate clients via such influences. All these government actions

that might not be explicitly classified as illegal falls well under corruption and unethical practice.

One of the major factors that result in the success of anti-corruption and anti-bribe acts is

that the development of incentives should be persistent and not one off, since such incentives

usually lack credibility because of an absence of legal enforcement via the authorities. In many

6
Sarah Lauwo, 'A Critical Examination Of The Multinational Companies’ Anti-Corruption Policy' (2012)
<http://visar.csustan.edu/aaba/Otusanya2012.pdf> accessed 1 May 2018.
 Page 16

instances they might also not work because certain people within the political arena lack the will

for enforcement, accountability, management, oversight and application because they are the ones

on the receiving end of such beneficial practices. Political will is a necessary tool for overcoming

bureaucratic, social and legal hurdles that might be present. In many cases both the support from

external and internal actors might led to the continuation of these problematic practices, and

governments might not be in the best possible position to tackle this on their own. For this,

empowerment of subsidiary departments like that of justice, law enforcement and malpractices

should be given this task of thorough tabulation and investigation of suspects. Companies should

also be given comparatively less privacy where they should disclose communication networks,

statements and other documentation for governmental review.

Part V: Conclusion

The problem of foreign corruption and multinational companies in United Kingdom and

Europe is twofold: on one hand while corruption is existing in a framework of impunity and

complacency, on the other the response towards policy implementation is uncoordinated and

patchy. The governments of these countries need to recognize that corruption is a big problem that

is plaguing activities surrounding multinationals, whether operating within their territory or not –

and that the facilitation of corruption is being carried out both directly and indirectly when

implementation of anti-corruption and anti-bribery acts are not being effectively carried out due to

the hurdles in place. The government needs to be responsible in tackling and curbing the

involvement of these multinationals in corruption, bribery, money laundering and other illegal

activities. Under this, when companies are caught in such malpractices, fines should not be their

only penalty as we have seen in the case of BAE that even millions of dollars in fine can be put

behind as it does not serve a blow to the company. Where the government is involved in facilitating
 Page 17

corruption via favoritism, lobbying, ineffective accountability, non-transparency etc. it should

strengthen its administrative and implementation system so that various anti-corruption acts can

be employed for the greater good of the society. The operation of companies headquartered in the

United Kingdom but involved in trade and operations in developing countries, the United Kingdom

Justice Department should keep a close check on invoices, processes employed, relations with

governments and development of communication networks to ensure that not only these

companies are not involved in any illicit activities but also that they are not ruining the reputation

of the country and businesses associated with the United Kingdom as a whole. Institutional

frameworks that provide a defense in favor of corruption should be done away with.
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References

Anwar, A and Deeprose G, "The Bribery Act 2010" (2010). Scots Law Times. Sweet &

Maxwell. 2010 (23). ISSN 0036-908X.

Clark C, 'BAE Systems To Pay $450 Million To Settle Allegations Of Bribery'

(Nytimes.com, 2010) <https://www.nytimes.com/2010/02/06/business/global/06bribe.html>

accessed 29 April 2018

Hock B, 'Foreign Bribery Enforcement: Credibility And Clarity Problems' (Global Trade

without Corruption, 2016) <https://www.oecd.org/cleangovbiz/Integrity-Forum-16-Branislav-

Hock.pdf> accessed 1 May 2018

Lauwo S, 'A Critical Examination Of The Multinational Companies’ Anti-Corruption

Policy' (2012) <http://visar.csustan.edu/aaba/Otusanya2012.pdf> accessed 1 May 2018

Milmo C, 'Hundreds of UK Companies Used to Facilitate Foreign Corruption worth Up To

£80Bn, Report' (iNews, 2017) <https://inews.co.uk/news/uk/hundreds-uk-companies-used-

facilitate-foreign-corruption-worth-80bn-report/> accessed 1 May 2018

Scheltinga C, 'United Kingdom Corruption Report' (Business Anti-Corruption Portal,

2018) <https://www.business-anti-corruption.com/country-profiles/united-kingdom/> accessed 1

May 2018