Comparison of UK AND US legislation

Introduction

The legislation is a key element for the understanding of our profession, its recognition and implementation of best practices. It is difficult to draw a strict boundary between political rights and human rights. Freedom of opinion is such a principle common to political rights and the Declaration on the Rights of Man and Citizen of August 26, 1789, which provides in Article 10 that "No person shall be molested for his opinions, even religious, provided their manifestation does not disturb the public order established by the Act.” To understand what political rights mean, broadly define; consider all the freedoms necessary for the functioning of a democracy. Thus, we conclude by pointing out that political rights vary by country, and they remain more developed in the so-called democratic regimes.

Discussion and Analysis

The U.S. is the global leader in enforcing anti-corruption legislation, while the U.K. has compared unfavorably in prosecuting individuals and corporations pursuant to the country's anti-bribery rules. The U.K. Bribery Act 2010 (the “Bribery Act”), which received Royal Assent on April 8, 2010, seeks to change that by overhauling the U.K.'s bribery laws and going beyond the U.S. Foreign Corrupt Practices Act of 1977 (“FCPA”) in several respects. As highlighted below, however, the broad scope of the Bribery Act creates several areas of uncertainty. Official guidance on these areas is expected in early 2011, prior to the Bribery Act's effective date in April 2011. The U.K. government expects corporations to use this period to bring their anti-corruption policies and programs into compliance with the Bribery Act. In addition seeking input from corporations in defining the “adequate procedures” required by the Bribery Act. The period of consultation is expected to close on November 8, 2010. Entities interested in participating in the consultation may visit www.justice.gov.uk. This alert highlights the key differences between the FCPA, as applied, and the Bribery Act, as written, and summarizes issues meriting consideration by affected entities (Sala, 2004, 813-3).

U.S Legislation

No doubt, the United States is the nation that depends more than any other non-profit organizations. In this context affects the qualitative aspect is particularly advanced, both the quantitative dimension that has no equal in the Western world and that stems from historical factors peculiar and distinctive relationship that binds these institutions to the government. The Italian environment still suffers from the great influence of the Catholic Church, the centrality of the family as an institution, the bureaucracy in politics and public administration, the tendency to encode and write the rules, fear of the dead hand. The other context however, originates from a much shorter history and dominated by the contrast between the historical and cultural ties with Britain. The rejection of any ties to gain independence as a people and as individuals. It is therefore , an environment that still shows signs of a great desire for autonomy and freedom, a strong influence of the Protestant religion, a preference for the unwritten law and custom, a strong tendency to volunteer and social solidarity, less ...