Homer Moyer discusses the United Kingdom's new Bribery Act 2010. Upcoming guidance on the law's requirements that companies have "adequate procedures" may resemble the sentencing guidelines for FCPA offenses. Even if companies implement bribery prevention programs, however, Moyer believes the "adequate procedures" defense could be a double-edged sword. "On the one hand, that provision is a powerful incentive for companies to have strong compliance programs," he says. "But the defense is also potentially a huge loophole for U.K. companies that pay bribes but that can cite an adequate compliance program." Overall, Moyer expects enforcement patterns in the U.K. to approximate those in the U.S.