Welcome back to the podcast, bribes, swindle, or steel.

We're continuing our review of the OECD anti-bribery landscape with a discussion about where

things stand with the UK.

Joining me on the podcast for the third time, I'm delighted to say, is Michelle de Kluva,

a partner with Adelschall Goddard's Global Investigations Group.

Michelle has extensive experience with financial crime investigations involving bribery, financial sanctions,

money laundering and fraud, and also advises clients on related compliance and governance issues.

And she, together with her firm, are an incredible

resource to trace as our partner law firm. Thank you for joining me, Michelle. Hi, Alexandra. It's

lovely to speak to you this afternoon. We're speaking about the UK's performance as a signatory

to the OECD Anti-Bribery Convention. We're going to focus primarily on the revised recommendation,

but perhaps you could start by giving us some background on the UK's accession to the convention.

The UK ratified the convention a long time ago in 1998, and it's been reviewed a number of times.

And I think we'll come on to what some of the

outstanding points are, but I think it's fair to say the UK is now broadly complying with

the convention. And I think the other thing I'd note about that sort of peer reviews that

have been conducted over the years is that the UK has generally been very responsive to the

recommendations. You see that, I think, in the history of the response to the various phases of the

reports. In the years prior to the implementation of the UK Bribery Act, the OECD's recommendations were really

focused on addressing the gaps in the pre-UKBA bribery regime. In the sort of first-phased

report, they were really critical about the fact that the existing legislation, its application

to foreign public officials was really unclear. And the other point that the working group really

...