Companies face bribery crackdown after new SFO rules The SFO had previously acknowledged that facilitation payments, small payments made to ensure public officials carry out functions they should normally do, were endemic in some countries and so would take time to eradicate. The new guidance simply states: "A facilitation payment is a type of bribe and should be seen as such." Previously the SFO had assured companies it would take into account factors such as whether a company has rules about entertaining, whether the expenditure is proportionate and how the expenditure was recorded by the company. Although the rules have been changed the SFO has attempted to reassure companies that under its new policy, "bona fide hospitality or promotional or other legitimate business expenditure is recognised as an established and important part of doing business." The final area to have changed is the approach the white-collar crime agency will take to companies that self-report corruption. Whereas under the previous director, Richard Alderman, the SFO had worked to reassure companies they would only be pursued under civil law if they report wrongdoing, the new rules are far more black and white. If on the evidence there is a realistic prospect of conviction, the SFO will prosecute if it is in the public interest to do so... Self-reporting is no guarantee that a prosecution will not follow. Each case will turn on its own facts.