Are there any grey areas?

Yes, according to Philip Urofsky, partner at the international law firm Shearman & Sterling and a former federal prosecutor for the US Department of Justice.

What if a company lists in the UK but doesn't have any physical operations here - is that carrying on business in the UK and so is it covered by the Act? he asks. The government seems to say no but it is a debatable point.

Then there is the issue of using contractors and subcontractors. The MoJ's guidance says you only have to perform due diligence on those who actually supply goods or services to you.

But if bribery is being carried out by a subcontractor below that first level and you know about it, then only doing one level of due diligence does not seem to qualify for the "adequate procedures" defence.

Another point for debate is the question of liability between a parent company and a subsidiary.

The guidance says that if a bribe has been paid by a subsidiary, and the benefit is solely to that subsidiary, then the parent company is not liable.

But Mr Urofsky argues that the parent clearly profits if a subsidiary does well. And he adds, if the parent company knew about the bribery, then surely the test should not be over profit anyway, but for culpability.