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[null,"Prepared By:","Contributors:"]
[null,"Arthur Cox","Richard Willis"]
[]
[]
[]
["Lex Mundi Global Anti-Corruption Compliance Guide"]
[]
["Report Generated: 11/19/2025"]
[]
["View your report results on next tab"]

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["Question","Ireland"]
["Anti-Corruption Compliance"]
["What is the key anti-bribery and corruption legislation in your jurisdiction?","The key Irish anti-bribery and corruption legislation is the \nCriminal Justice (Corruption Offences) Act 2018 (the“\nAct”)\n. \n"]
["Has there been a specific anti-bribery and corruption law enacted in your jurisdiction in the last ten years?","The \nAct was commenced on July 30, 2018. Prior to this, Irish anti-bribery and corruption legislation was encompassed in the \nPrevention of Corruption Acts 1889-2010. The \nAct repealed and replaced the \nPrevention of Corruption Acts 1889-2010 and consolidated the same into a single piece of legislation.  \n"]
["Is a bribe payment to domestic government officials prohibited by the legislation?","Yes. Section 5 of the \nAct provides for the offense of active and passive corruption. \nSection 5(1) states that a person who, either directly or indirectly, by himself or herself or with another person \n(a) corruptly offers, or\n(b) corruptly gives or agrees to give,\na gift, consideration or advantage in order to induce another person to exert an improper influence over an act of an official in relation to the office, employment, position or business of the official is guilty of this offense.\n‘Corruptly’ is defined under the \nAct to include acting with an improper purpose either personally or by influencing\n\n\nanother person, whether:\n\n\n(a) by means of making a false statement,\n\n\n(b) by means of withholding, concealing, altering or destroying a document or other information, or\n\n\n(c) by other means.\nThis offense thus includes a bribe payment to a domestic government official. \nSection 6 of the \nAct created a further offense relating specifically to trading in influence. A person who, either directly\n\n\nor indirectly, by himself or herself or with another person\n\n\n(a) corruptly offers, or\n\n\n(b) corruptly gives or agrees to give,\n\n\na gift, consideration or advantage in order to induce another person to exert an improper influence over an act of an\n\n\nan official in relation to the office, employment, position or business of the official is guilty of this offense.\nFurthermore, \nsection 7 of the \nAct prohibits an Irish government official from doing any act in relation to his or her office or position for the purpose of corruptly obtaining a benefit. \nIn addition,\n Section 8 of the \nAct relates to the giving of a gift that facilitates the commission of an offense, which would include a bribe. A person who gives a gift, consideration or advantage to another person where the first-mentioned person knows or ought reasonably to know that the gift, consideration or advantage, or a part of it, will be used to facilitate the commission of an offense under the \nAct, is guilty of this offense.\n"]
["Is a bribe payment to foreign government officials prohibited by the legislation?","Yes. \nSection 5 of the \nAct applies to gifts, consideration or advantages offered or given as an inducement to, reward for, or otherwise on account of, any person doing an act in relation to his or her office, employment, position or business. This would include foreign government officials, provided that the person committing the offense is subject to the legislation (as discussed further below).  \nSection 6 of the \nAct also applies where a person corruptly offers, gives or agrees to give, a gift, consideration or advantage in order to induce another person to exert an improper influence over an act of a foreign government official in relation to their office, employment, position or business.\n"]
["Is requesting or accepting a bribe prohibited by the legislation?","Yes. A person who, either directly or indirectly, by himself or herself or with another person\n(a) corruptly requests,\n\n\n(b) corruptly accepts or obtains, or\n\n\n(c) corruptly agrees to accept,\n\n\nfor himself or herself or for any other person, a gift, consideration or advantage as an inducement to, or reward for, or otherwise on account of, any person doing an act in relation to his or her office, employment, position or business is guilty of an offense under \nSection 5(2) of the \nAct. \nFurther, \nSection 7 of the \nAct prohibits an Irish official from doing any act in relation to his or her office or position for the purpose of corruptly obtaining a benefit. \n"]
["Who is subject to the legislation?","The \nAct applies both to individuals and corporate bodies resident in Ireland however the \nAct also has an extraterritorial element.  \nPursuant to \nSection 11 of the \nAct, a person or corporate body can be prosecuted for an offense under the \nAct if any of the acts alleged to constitute the offense are committed in Ireland (or on an Irish ship or an Irish registered aircraft), even if the other acts constituting the offense were committed outside Ireland. \nSection 12 of the \nAct provides that, in certain circumstances, where a person does an act in a place outside Ireland that, if done in Ireland, would, constitute an offense under \nSections 5, 6, 7, 8, 9 or 18(1) of the \nAct, they shall be guilty of an offense.  This applies to acts committed on board an Irish ship; on an Irish registered aircraft; or where the act constitutes an offense under the law of the place where it was done and the person concerned is (a) an Irish citizen; (b) an Irish official acting in his or her capacity as such; (c) an individual who has had his or her principal residence in Ireland for the period of 12 months immediately preceding the alleged commission of the offense concerned; (d) a company; or (e) any other body corporate established under Irish law.\nFurther, where a European Union (EU) official working for an EU institution or body set up in accordance with the treaties of the EU which has its headquarters in Ireland does an act outside Ireland that would, if done in Ireland, constitute an offense under \nSection 5 of the \nAct and if that act constitutes an offense under the law of the place where it was done, that official shall be guilty of an offense. \nA person may also be guilty of an offense under \nSection 5(1) of the \nAct in respect of acts committed outside the state if the person to whom they are corruptly offering a gift, consideration or advantage is (a) an Irish citizen and (b) a national official of a European Union Member State or a European Union official. In this instance, in order for the offense to occur, the act must also be an offense under the law of the place where it was done.\n"]
["Is there criminal liability for corporate entities who have either paid or accepted a bribe payment?","Yes. Under \nSection 18(1) of the \nAct, a body corporate will be guilty of an offense if an offense under the \nAct is committed by\n\n\n(a) a director, manager, secretary or other officers of the body corporate,\n\n\n(b) a person purporting to act in that capacity,\n\n\n(c) a shadow director within the meaning of the \nCompanies Act 2014 of the body corporate, or\n\n\n(d) an employee, agent or subsidiary of the body corporate, with the intention of obtaining or retaining either business for the body corporate, or an advantage in the conduct of business for the body corporate.\nIt is a defense for a company when faced with a prosecution under \nSection 18(1) of the \nAct to show that it took “all reasonable steps and exercised all due diligence” to avoid the commission of the offense.\nIn addition, \nSection 18(3) of the \nAct provides for a derivative offense whereby if it is proven that the corporate offense was committed with the consent, connivance or wilful neglect of a person who was\n\n\n(a) a director, manager, secretary or other officers of the body corporate, or\n\n\n(b) a person purporting to act in that capacity,\n\n\nthat person will, as well as the body corporate, be guilty of an offense and will be liable to be proceeded against and punished as if they were guilty of the first-mentioned offense.\n"]
["What is the penalty for individuals violating the law?","On summary conviction, penalties range from a fine of up to €5,000, a term of imprisonment of up to 12 months and/or forfeiture of property of the value of the gift or benefit obtained in connection with the offense.  \nOn conviction on indictment, penalties range from an unlimited fine, a term of imprisonment of up to 10 years and/or forfeiture of property of the value of the gift or benefit obtained in connection with the offense. In certain circumstances, the court may also order an Irish official to forfeit their office and prohibit them from holding office as particular Irish officials for up to ten years. \n"]
["Assuming corporate entities are liable for violating the legislation, what is the penalty for corporate entities violating the law?","If convicted, a body corporate is liable to a fine of up to €5,000 on summary conviction or an unlimited fine on conviction on indictment.\n"]
["Assuming corporate entities are liable for violating the legislation, does having a compliance program designed to prevent bribery constitute a defense?"," Section 18(2) of the  Act provides that it shall be a defense for a body corporate to prove that it took all reasonable steps and exercised all due diligence to avoid the commission of the relevant offense under the Act .  \n\n In the event of a prosecution, a company’s compliance program and anti-corruption policies and procedures are likely to come under scrutiny and may prove critical where a company is seeking to rely on this defense. \n\n Bodies corporate should ensure that, at a minimum, the following steps are taken in order to minimize the risk of conviction: \n\n \n\t put in place clear and comprehensive anti-corruption policies and/or review existing policies already in place;  \n\t ensure all personnel receive training on the said policies and are aware of their obligations pursuant to the policies and how to recognize and deal with suspected bribery; \n\t discuss and review on an ongoing basis the effectiveness of the policies and procedures at the appropriate level within the organization (e.g. compliance or board level);  \n\t appoint a compliance manager with day-to-day responsibility for implementing the policies, monitoring their use and effectiveness and updating them as necessary; \n\t keep a written record of any gifts or entertainment given or received in order to ensure transparency; and \n\t communicate the organization’s zero-tolerance approach on bribery and corruption to third-party service providers, suppliers and other organizations with which it does business. \n \n"]
["Assuming corporate entities are liable for violating the anticorruption law, is it possible for a corporate entity to reach a deferred prosecution agreement or leniency agreement with the enforcement authorities?","In Ireland, neither deferred prosecution agreements nor leniency agreements are currently available to corporate entities in respect of a violation of anti-corruption laws.\n"]