Cci april 10.pmd

Alerting business to threats from fraud and corporate crime
Be wary of ‘jack of all trades’ online commodity traders says FIB oil, diesel, petrol, coal and cement.
FBI, ICC and Interpol if a ‘not real’ used to add credibility to the deal.
In This Issue of CCI
and after “checking with guys inthe UK” was virtually asked what COMMERCIAL CRIME
CORRUPTION
CYBERCRIME
securities.org.uk) to pull people in.
styles of correspondence fromLondon Securities and PCL areidentical, right down to the spurious The supplied contract, meanwhile, was a complete work of fiction, which looks as if it were cobbled together by a dyslexic 10 year-old. The figures are confused and in cases wrong. Buyer/seller responsibilities are mixed up. No product origin is named, yet a price of $1.2/kg is quoted CIF for a 20Mt load. Finally, there is the classic fraudster’s reference to a Letter of Credit that is ‘Irrevocable, Transferable, Devisable’ (misspelt). On top England, that went into liquidation.
of all this, the buyer has since discovered that the bank account nominatedfor payment is a Bank of South Africa savings account that has not been With evidence like this, a prudentperson would be forgiven for walk- The FIB suspects this trader is more amateur chancer than seasoned commodities fraudster, but there are plenty of others out there better prepared. The buyer in this case withdrew before paying any money.
He now says he has negotiated a new deal with a Chinese company that he is sure is legitimate. Based on its past dealings with online commodities traders, the FIB remains to be convinced.
More information online at www.icc-ccs.org
hold/block funds, not transfer them.
application after the deposit is paid.
rest of the fraud is able to play out.
London Securities and its principles.
to support a $100m loan transaction.
More information online at www.icc-ccs.org
Committing financial fraud: accident or design An article in last October’s CCI told the story of how Stephen Greenspan became one of Madoff’svictims. This month it’s the turn of a fraudster to explain why and how. You will be able to hearmore about fraudsters and why they commit their crimes at the 10th CCS Annual Lecture, entitled“Learning from Fraudsters”, which will be presented by leading criminologist Professor Martin Gillin London on the 17th June. among their key mis-takes they wrote cheques they’re given,” he said. “The policy More information online at www.icc-ccs.org
securities fraud scam – some formof Ponzi scheme - because hedidn’t have to worry about paying out dividends since the financialinstruments he sold had not yet matured. That also helped himavoid detection.
But there are things the investorscould have done to protect them- selves, he said. For instance, hisclients would have known he had not purchased their annuity if theyhad called the insurance company that issued it to verify the purchase,rather than relying on the documents also offer online access to theaccounts that allow customersto verify information.
SuspicionsThe beginning of the end for Lake’sscheme came when one of his Getting inside the mind of a financial fraudster is both intriguing and exciting. Why do they do it? How do they do it? This year’s lecture aims to answer these and many other questions about how fraudsters work, what they think, and how they respond when the game is up. Lecturer, Professor Martin Gill, is a leading criminologist who has studied fraudsters for many years, and has sought to understand how they operate. He will be accompanied by a convicted fraudster who will give insights into how and why he got into fraud, the impact of prison etc, and delegates will have an opportunity to ask questions. The Lecture should be both fascinating and illuminating, and potentially one of the most interestingCCS has ever staged.
At his trial, prosecutors contendedthat Lake only volunteered informa- There’s a new venue and new sponsors this year too. The conference room at the Dickens Inn looks out over the picturesque St Katharine’s Dock in the heart of the city and will be the ideal location to spend a few hours on a pleasant summer’s evening.
authorities. But Lake says she hadno impact on his decision. If he Co-sponsor QEB Hollis Whiteman, is widely recognised as one of the leading sets of barristers’ chambers in the country, specialising in crime, a fake tax statement, which wouldhave allowed him to avoid detection Co-sponsor PCB Litigation is a firm of internationally renowned lawyers that specialise in fraud and international commerce litigation, andcorporate fraud risk management. The firm is one of the founding authorities when he realised justhow much he had stolen and that Now widely regarded as a must attend event, this year’s CCS Annual Lecture gets underway at 4.00pm with the main presentation at 6.00pm.
There’s a wine reception afterwards to discuss its content and ample opportunity for networking or simply enjoying the ambiance of St Katharine’s and the buzz of the Dickens Inn.
back to Questar. He says he willdo this by driving a tractor-trailer As usual, attendance is by invitation only and there is no charge for attending. CCS members should receive their invitation in the coming weeks, which will include details on how to register.
More information online at www.icc-ccs.org
Commercial Crime
Sri Lanka: a commercial crime hotspot in the making Sri Lanka is hoping to capitalise on its natural beauty to become a tourist hotspot, giventhat its three-decade long bloody civil war is now over. But Munza Mushtaq reportsfrom Colombo that because of ignorance on the part of local authorities, the countrycould become a hotspot for something far less welcome - commercial crime. With peace in place after the Tamil Tigers were facing fraud charges. Kotelawala is now out on bail but destroyed as a fighting force last May by the Sri Lankan his wife, who also functioned as the deputy chairman of army, this island nation has just begun to recover from the group, fled the country and is still in hiding. To date, civil war and work towards economic stability.
none of the depositors from both cases have beenrefunded. Colombo is already the country’s commercial as wellas political capital and is aspiring to be an Asian Absconding abroad is an effective tactic by Sri Lankan commercial hub for some of the world’s leading commercial crime suspects, beyond the reach of the multinationals, as well as local conglomerates.
national police’s Criminal Investigations Department Yet back-to-back large-scale financial frauds running (CID) and Fraud Bureau. A senior police officer, who into billions of dollars have rocked the country over spoke on the condition of anonymity, stressed that while the past few years, and with the chief culprits yet to be action could be taken if fraudsters were in the country, apprehended risk analysts warn Sri Lanka is becoming it was “impossible” to go after them outside the island.
increasingly vulnerable to large-scale scams, corruption “Even though we seek the assistance of Interpol, and embezzlement. Despite this growing menace, many in comparison to more ‘important issues’ such as Sri Lankans including the recently re-elected President terrorism, focus on apprehending such fraudsters Mahinda Rajapaksa and his government appear com- is still at minimalist levels,” he noted.
placent about the risks posed by commercial crime.
Political interference can also undermine the independ- As the war started its violent end game, 2008 was ence of police investigations into commercial crime.
a bad year for Sri Lanka regarding business crime – According to the officer, often, when a person is taken it was rocked by two back-to-back financial scams, into custody or an investigation is launched into a ‘close which made headlines even abroad. In September 2008, associate’ of a high level politician (maybe from the thousands of unsuspecting depositors fell prey to a ruling party), the police come under immense pressure Ponzi-scam fraudster who fled abroad after duping thousands of people into depositing money with hisfirm by promising high returns.
The law enforcement officer’s concerns were echoed bya leading Sri Lankan lawyer and anti-corruption activist The fraudster, Sakvithi Ranasinghe, currently on Nihal Sri Ameresekere, who is a member of the Interna- Interpol’s wanted list, had offered returns as high as tional Association of Anti-Corruption Authorities.
30% on his investments, in contrast to the general 18%and lower offered by recognised banks and financial “The police are often not allowed to take action against institutions. He defrauded around 5,000 unsuspecting the offenders simply because they belong to an influen- depositors of more than Sri Lanka Rupees 1.5 billion tial group,” Ameresekere pointed out. He added that even though Sri Lanka had laws against commercialcrime, the failure by the authorities to implement these Just two months later, in December 2008, a similarly laws to the book have led to a situation where fraud, shocking fraud of larger proportions unfolded, this time involving the Golden Key Credit Card Company, a wellrecognised and highly respected company on the “We have laws but there is no proper law enforcement in the country. Only if it is politically motivated and pushedwill there be an investigation and even prosecution, This fraud has been highlighted as the biggest white not otherwise. If the politicians don’t want a certain collar scam in the history of Sri Lanka, where thousands individual prosecuted, there are times that the investiga- of depositors were allegedly defrauded of approxi- tion is scuttled clandestinely,” Ameresekere claimed.
mately 20 billion Sri Lankan rupees (US$175 million)in another Ponzi-style scheme that was uncovered as He also insisted that neither of Sri Lanka’s main two the global financial crisis struck hard. Several officials political parties are serious about fighting corruption of the company, including the chairman of the group or commercial crime; simply because they are funded Lalith Kotelawala, have been remanded in custody and financed by the commercial world.
More information online at www.icc-ccs.org
Commercial Crime
“There are people above the law, and the law will nottouch those people, no matter what fraud they commit,”the anti-corruption activist declared.
And this is a problem: “Failure by the authorities to take stringent measures to address this growing problem willlead to a general setback in business confidence the world over. Serious foreign investors will rethink beforecoming and investing in Sri Lanka if they think the rule ICC Commercial Crime Services has developed of law does not apply to all in a fair manner,” he said.
a new three-day course on intelligence analysis.
The inaugural course will run from 7 – 9 June 2010, Despite his misgivings over policing, Ameresekere at the Tower Hotel in London. It should be argued that it was still worth Sri Lanka upgrading and popular and places are limited, so early registration modernising certain existing laws. He said the country followed some criminal laws passed in the 1950s.
In today’s fast moving world getting access to the The lack of a multi-faceted sophisticated investigations right information quickly and cheaply has never been unit to fight and combat commercial crime may also more important for commercial success. However, it is prove to be detrimental to the country, as neither not enough to just have information; it needs to sifted the general police nor the CID generally undergo and analysed to ensure that its value is maximised specialised training to investigate issues related This new course will provide delegates with: Rampant counterfeitingMeanwhile, the Chief Executive Officer of the Interna- tional Chamber of Commerce (ICC) Sri Lanka, Gamini Peiris disclosed that, the island nation was not far behind China and Russia in the counterfeit business.
for collecting and analysing raw information “We are now a transit point for counterfeit goods, but if the customs are educated and vigilant, then we can stop this from becoming a larger problem,” he noted.
and critical path analysis.
Training in financial analysis, strategies Due to the excessive fake product circulation in the market, Sri Lanka also risks losing foreign exchange owing to branded companies not wanting to investin the island due to the excessive circulation of fake In addition, each delegate will receive a comprehen- products. “We are losing foreign exchange and employ- sive e-manual, as well as a certificate of attendance.
ment opportunities due to this situation,” he said.
Highly practical and interactive, the course will be led According to Peiris, some money from counterfeiting by Jim Devery, a well-known and highly regarded businesses may even be going for the funding of expert with a wealth of experience in this field.
terrorist organisations, including what is left of theLiberation Tigers of Tamil Eelam (LTTE). “We are already It should be of interest to a range of different showing signs of being a commercial crime hot spot,” Corporate security professionals in banks, However, Senior Vice President of the Federation of Chambers of Commerce and Industry of Sri Lanka, Fraud investigators, accountants and analysts Tissa Jayaweera, who also functions as the Chairman of the International Chamber of Commerce’s Sri Lanka branch, emphasised that Sri Lanka could head off this Government and private sector investigators unwelcome development if there was state vigilance.
“But the state is clueless and it is not vigilant,” he said.
“We need strong laws to fight this problem,” he said, More information and a registration form can be found adding that implementation was still the key: “We have laws, but they are not enacted – there is politicalpatronage, this should stop: law should apply to all,”Jayaweera noted.
More information online at www.icc-ccs.org
Corruption
Fighting Bribery: New UK legislation explained The UK is stepping up its fight against bribery and corruption with new legislationdue to be enacted this spring. The Bill will have a significant impact upon businesses,which are likely to have to respond by tightening up their procedures. It coverscommercial bribery as well as public officials, and it makes it much easier toprosecute companies. It extends UK jurisdiction to prosecute offences committedanywhere in the world, and hospitality and facilitation payments caught by the lawface penalties of up to 10 years’ imprisonment if convicted. The Bill is anotherweapon in the ever-growing armoury of prosecutors and investigators to dealwith commercial crime. Sean Larkin, a barrister with QEB Hollis Whitemanin London explains. Despite recent successes, the existing law is consid- will be caught by the new Bribery Bill is much wider.
ered out of date and will soon be replaced by a new Henceforth, it will not matter that the bribe may be Bribery Bill. It is the result of many years of activities offered/paid or received outside of the UK, have no against bribery and corruption. Some recent examples connection with the UK, and any performance affected take place outside the UK. The UK authorities mayprosecute as long as the individual responsible is BAE Systems agreed to admit criminal charges ordinarily resident in the UK or, if a corporate entity, and pay fines of some £286m to settle probes by has a permanent establishment, subsidiary or other US and UK authorities. The decision has provoked operation in the UK. The courts will disregard local controversy and is subject to judicial review.
custom [unless permitted or required by local law] and The prosecution of Mabey & Jonson, whose self- expectation, and apply the test of what a reasonable reported offences of overseas corruption has lead to person in the United Kingdom would expect in relation fines, reparation payments and compliance monitoring.
Its former chief is currently subject to criminal chargesarising from that investigation.
The £5.25m fine by the Financial Services Authority The corporate offence is committed where a person (A), (FSA) imposed on Aon Limited (Aon Ltd) for failing to who is associated with the commercial organisation (C) take reasonable care to establish and maintain effective [which means he performs services for, or on behalf of systems and controls to counter the risks of bribery C], bribes another person with the intention of obtaining and corruption associated with making payments or retaining business or an advantage in the conduct of business for C. Clearly, this does not just cover The conviction and custodial sentence levied employees but a range of agents. The definition of against a Managing Director from who bribes were There is no doubt that for many years businesses have made payments either to obtain work or to facilitate the provision of services. The new Bill will, in rough terms, make all such payments criminal. If the payment is made by a person associated with the business a corporate offence. Senior management may for business purposes, both the individual and the be criminally liable if the company is found guilty business will automatically be guilty. The business and they consented or connived in the criminality.
will have a defence if it can prove it had ‘adequate The sentence will be up to 10 years’ imprisonment.
procedures’ in place to prevent such offences.
In summary, the test involves the use of an advantage However, the real problem is that no one knows what [not necessarily financial] to induce or reward improper ‘adequate procedures’ are. The sorts of issues thrown performance of a function caught by the Act, which up include: Who defines what is adequate? If bribery also includes work related functions.
does take place irrespective of the procedures, canthey be said to be adequate? How can a commercial organisation be confident it does have adequate Ordinarily, an offence can only be prosecuted in the UK procedures in place before investigation? if all or part of it was committed in the UK. For example,if one shoplifted in France, it would be a crime in France but not a crime prosecutable in the UK. The activity that The government realises that guidance is essential.
More information online at www.icc-ccs.org
Corruption
The Serious Fraud Office [SFO], the lead agency in put adequate procedures in place in advance. If in dealing with bribery, will publish guidance that will any doubt businesses should engage with the SFO.
be available before the relevant offence is enacted.
Similarly, if a business suspects a crime has been Lord Bach, on behalf of the government, has referred committed it may be an advantage to have conducted to information from reputable organisations as being an internal investigation, and if an offence found the a useful source of guidance and suggested that business should self-report it to the SFO.
guidance from GC100 might help inform the debate.
Importantly, the fact of having self-reporting and It is thought that some assistance may be gained assurance of systems in place will affect the decision from sentencing guidelines in the US, which has had a to deal with it criminally as opposed to civilly, the scope similar law for many years. According to US Sentencing of liability, and the size of the fine. The SFO has pro- Guidelines, a “compliance and ethics program shall be duced guidance on self-reporting by companies, which reasonably designed, implemented, and enforced so is available on their website. The Mabey and Johnson that the program is generally effective in preventing case is an example of an internal investigation leading and deterring criminal conduct.” The following elements to self-reporting and a civil settlement for the company, are critical to a comprehensive compliance program: albeit the directors have been criminally charged.
The extension of jurisdiction means that businesses may be liable to prosecution by more than one country.
• establishment of policies and procedures Prosecuting authorities are looking to arrange global settlements [e.g. BAE case] where one country usually • high level involvement with a specific individual takes the lead and the agreement settles all liability • education and training• monitoring, auditing, and evaluation As can be seen, the Bribery Bill is likely to have a significant impact on many businesses, and as such it will require an appropriate response to avoid protracted investigation and prosecution.
Of further concern to business should be the govern- ment’s attitude towards corporate hospitality andfacilitation payments. The House of Lords considered The US Securities Investor Protection Corp (SIPC), adding a defence regarding corporate hospitality but the agency that keeps a reserve fund for investors of in fact no defence has been added, although Lord insolvent brokerages, warned last month that a copy Tunnicliffe provided some comfort by writing: ‘We of its website targeting defrauded Madoff investors recognise that corporate hospitality is an accepted part has been set up by a phantom organisation.
of modern business practice and the Government is notseeking to penalise expenditure on corporate hospitality The copycat site, www.I-SIPC.com - I for International - for legitimate commercial purposes. However, lavish had a link to a picture of a large stack of US currency corporate hospitality can also be used as a bribe under the headline, “ISIPC & Interpol Discovers $1.3 to secure advantages and the offences in the Bill billion hidding by Madoff in Malaysia.” (“Hidden” was must therefore be capable of penalising those who misspelled on the site, which has since been replaced by a note that it is temporarily unavailable).
A ‘facilitation payment’ refers to the practice of paying a In a statement, SIPC warned investors not to provide small sum of money to a public official (or other person) personal or financial information on the site, which has as a way of ensuring that they perform their duty, either a Geneva mailing address. One passage, with spelling more promptly or at all. The Bill provides no such or grammatical errors, claims to have interviewed exception unlike the US equivalent. Although it is Madoff. “We have being tracking this stolen fund for unlikely that a small facilitation payment, extorted by a couple of months but after concrete information got foreign official in countries where this is normal practice, to us that Madoff might have hiding some funds in would of itself give rise to prosecution in the UK, the various discrete locations our teams interrogated some matter is one that will be a matter for guidance and of Madoff past workers and with the interview we had with Madoff last month we were able to conclude ourinvestigation,” the site said.
Prevention proceduresThe prosecuting authorities, particularly the SFO, wish SIPC President Stephen Harbeck said there were some to avoid offences being committed rather than reacting indications the bogus site may have origins in Nigeria, once committed. They expect that businesses will and that it had some aspects of “recovery room” frauds.
More information online at www.icc-ccs.org
Cybercrime
The possible financial and commercial consequences of the loss of sensitive customer data or confidential corporate information are farreaching. Organisations need to be fully aware of the risks of losing potential “toxic liability” to an Such data is typically lost through carelessness, lack of training or theft.
Furthermore, the loss of employee data is likely to be in breach of theData Protection Act. This could leave an organisation open to legal claims by the employees and customers affected (if they can establish financial loss) or, alternatively, complaints to the Information Commissioner, who regulates this area. Brand damage aside, the damage to the morale and confidence of employees and customers could be substantial, further Barely a month passes without an organisation, frequently in the publicsector, suffering damaging publicity through data loss. The widespread use of service providers also causes further complications, with third parties (such as contractors or suppliers) responsible for the loss of The most important piece of legislation to be aware of is the Data Protection Act 1998 which, among other things, sets down a number of principles for handling sensitive and personal data, such as: Data should be processed fairly and lawfully Data should be adequate, relevant and not excessive in relation to the purpose or purposes for which it is processed Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal data “The Legal Risks of Data Loss” Business should be aware that an individual who suffers damage by reason of any contravention by a data controller of any of the require- ments of the Data Protection Act is entitled to compensation from the Organisations should also be mindful of the powers of the InformationCommissioner to impose fines for deliberate or reckless breaches ofthe Data Protection Act. This power was granted to the InformationCommissioner in May 2008 under the Criminal Justice and ImmigrationAct – a clear signal that data protection must become a priority.
Additionally, while the Human Rights Act 1998 is only directly enforceable against public authorities, private sector employers need to at least be aware of an individual’s right to respect for their private and family life, their home and their correspondence.
held on 27th – 29th April in itsnew venue Earl’s Court, London.
A final consideration is any contractual obligation that might have been breached by the unauthorised disclosure of information. For example, an organisation might have entered into a contract with a third party, which incorporates terms relating to how the third party’s data will be secured or processed. Should these terms have been breached by any data loss incident, then the third party may take legal proceedings for breach of More information online at www.icc-ccs.org
Cybercrime
the potential loss of data, while implementation of data The Information Commissioner (www.ico.gov.uk) security policies is often patchy. The use of third parties regulates this area and while the Codes of Practice that is also identified as a potential point of weakness, with are issued are for guidance and not binding legislation, firms generally relying too much on assumptions that they will always be considered by Courts or Tribunals contractual terms were being met, without actually in determining proceedings in relation to any breach Over-riding everything, it is the data controller who will The guidance covers a number of important areas for still ultimately needs to comply with the principles set organisations that handle personal information and stresses that any organisation should analyse thepotential risks that might flow from an unauthorised disclosure of the information, including: Important data, whether relating to customers,an organisation itself, or its employees, is clearly • Identifying specific staff who have responsibility necessary for any organisation to function. To paraphrase the Information Commissioner, such data • Implementing appropriate security and organisational can be (and often is) both a crucial asset and a toxic measures to ensure the safety of such data (both liability. The challenge for all organisations is to assess the risks that they face, bearing in mind the categories • Considering the appropriate levels of security to be of the data held, consider the possible consequences applied, such as encryption or password protection of any data loss, and then put in place appropriate andproportionate protections, both technical and physical, It also concurs with the Financial Services Authority to ensure the security of the data as much as is (FSA), which produced a specific report as a result of a review of industry practice and standards in managingthe risk of data loss, that customer data must not be As the Information Commissioner acknowledged in an taken off site on laptops or other portable devices that interview he gave in October 2008; “things will inevitably are not encrypted; failure to comply can see the FSA go wrong, therefore you should plan for things going wrong.” Organisations have to become more awarethat holding large elements of personal data creates Furthermore, it highlights that many firms do not a significant risk and therefore substantial protective undertake appropriate risk assessment regarding measures are needed in order to secure that data.
PROSECUTORS in America have indicted four California QinetiQ recently launched a new online system that will men they accuse of using a network of computers and keep EU investigations secure and anonymous, whilst automated software to buy up online tickets to concerts protecting communications between investigators and and sporting events and selling them at a profit. The informants. The web-based secure Fraud Notification four are alleged to have made more than $25 million system is currently being operated by the European between 2002 and 2009 by re-selling more than Anti-Fraud Office (OLAF). It allows the office to receive 1.5 million of the “most coveted tickets” to concert tip-offs and maintain communications during an investi- performances, shows and major sporting events.
gation while completely protecting the anonymity of theinformant.
Operating as Wiseguy Tickets, the men allegedlytargeted Ticketmaster, Tickets.com, MLB.com, The problem of anonymity was solved by designing MusicToday, and other online ticket vendors. They are a system which enables a simple and secure means accused of hiring programmers in Bulgaria to create of communication. On entering the OLAF website, a nationwide network of computers that impersonated the user is guided through the completion of a individual visitors to the ticket vendor sites, flooding questionnaire. This is the only information that an OLAF the sites at the exact moment that the tickets went investigator ever sees; even the IP address is masked on sale. The network of computers, dubbed Captcha and cannot be identified. An informant can exit the bots, automated and sped up the buying process system after completing the questionnaire and is not by completing Captcha tests the sites presented that required to have any further communication with the were designed to keep automated bots off the sites.
OLAF team. However, if they do agree to ongoingcommunications, a clever encryption system, which is The men also are accused of creating shell corporations unique to each informant and each OLAF investigator, with fake domains and email addresses and aliases means that the identity of the informant is protected at to deceive the online ticket vendors.
all times, wherever and whenever they use the system. More information online at www.icc-ccs.org
Automation of hacking presents ever greater threat organisations for the sake of profit.
• Farmers: A farmer’s primary
• Dealers: Dealers are tasked
University of Oxford and more.
Ironically, this technique is the mostprevalent method used to createhavoc in cyberspace, yet remainsvirtually unknown to the generalpublic,” explained Imperva CTOAmichai Shulman.
Published monthly by Commercial Crime Services, Cinnabar Wharf, 26 Wapping High Street, London E1W 1NG, UK.
Tel: +44 (0) 20 7423 6960 Fax: +44 (0) 20 7423 6961 Email: [email protected] Website: www.icc-ccs.org Editor: Andy Holder Email [email protected] attacks. On the organisation struc-ture, it says that a clear definition No part of this publication may be reproduced, stored in a retrieval system, or translated in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise without the prior permission ofthe publishers.
developed to form a supply chainthat resembles a drug cartel.
While every effort has been made to check the information given in this publication, the authors, editors,and publishers cannot accept any responsibility for any loss or damage whatsoever arising out of, or caused by the use of, such information. Opinions expressed in Commercial Crime International are those of the individual authors and not necessarily those of the publisher.
Copyright 2010. All rights reserved.
• Researchers: A researcher’s

Source: http://www.qebholliswhiteman.co.uk/articles-pdfs/fighting-bribery---new-uk-legislation-explained.pdf