Working Paper 55: Compensating the victims of foreign bribery

The UK is a global leader in its efforts to target foreign bribery. It is one of the only countries worldwide to use negotiated settlements such as deferred prosecution agreements (DPAs) to resolve cases and extract penalties from corporations that commit corruption abroad. The UK has also laudably committed to using the proceeds of DPAs in foreign bribery cases to compensate the victims of corruption, particularly in countries that suffer its worst effects. This paper explores why the UK’s policy of compensating the victims of foreign bribery is not achieving its intended results in practice, and proposes realistic suggestions for improvement to the extant DPA regime. It examines the conceptual, practical and political difficulties inherent in this undertaking, shining a light on how victim compensation operates in the UK and analysing judicial decisions on this issue. Finally, the paper proposes reform recommendations to strengthen the DPA regime to ensure appropriate compensation is made in foreign bribery settlements. About this report The paper is published as part of the Basel Institute on Governance Working Paper series, ISSN: 2624-9650. You may share or republish it under a Creative Commons BY-NC-ND 4.0 International Licence. The paper is intended for general informational purposes and does not constitute and/or substitute legal or other professional advice. The contents are the sole responsibility of the author and do not necessarily reflect the official position of the Basel Institute on Governance, its donors and partners, or the University of Basel. Suggested citation: Hickey, Sam. 2025. ‘Compensating the victims of foreign bribery: UK legislation, practice and recommended reforms.’ Working Paper 55, Basel Institute on Governance. Available at: baselgovernance.org/publications/wp-55. A version of this paper is also published by the Transnational Criminal Law Review.