Some 20 years ago I attended a “contentious” meeting at the European Commission with a client. After the prelims the Commission officials asked the client (in front of me) whether it would not be better to invite the lawyer to leave the room. If this was unacceptable then, today it would be unthinkable. Over the ensuing 20 years the Commission’s procedures have been strengthened, the rights of defence have been codified in the EU Charter of Fundamental rights; and the Court of Justice of the EU has made judicially clear the absolute obligations of EU institutions and Member States to respects rights of defence when EU law is in issue.

The UK Bribery Act 2010 comes into force on 1 July 2011 following the publication, at the end of March, of detailed guidelines and intended effects of the Act.  In addition separate prosecution guidelines have been published by the Serious Fraud Office which explain when prosecutions are likely. Both documents are of central importance given the very wide scope of coverage of the Act.