Alexis, I agree with you. The UK Anti-Bribery Act is a bit more stringent whereas the FCPA’s provision is not sufficient as it lacks the inclusion of all parties involved in a bribe. Basically, it takes two to tango especially when it comes to corruption. The giver and receiver both participated in the bribe, therefore should be held equally liable. Offering payments to a foreign official attracts people to conduct illegal transaction, especially in developing countries. To your point, I believe the FCPA would be a much stronger Act if it can include both the parties involved in the bribe. If the receiver would be liable under the FCPA for accepting a bribe, I would think the receiver would think twice to accepting the offer of a bribe or
