Bribery and money laundering sit at the sharp end of professional ethics: criminal penalties, regulatory sanctions and the loss of RICS membership are all live risks. Panel assessors raise them because they test whether you understand that chartered surveying carries direct legal obligations under the RICS Rules of Conduct 2022 and several pieces of primary legislation. You should be prepared to explain both regimes, apply them to realistic scenarios and demonstrate that you would know what to do if you encountered either in practice.

The Bribery Act 2010: Key Offences

  • Section 1 — Bribing another person. Offering, promising or giving an advantage to induce or reward improper conduct.
  • Section 2 — Being bribed. Requesting, agreeing to receive or accepting such an advantage in connection with improper conduct.
  • Section 6 — Bribing a foreign public official. A standalone offence targeting payments intended to obtain or retain business. There is no need to prove improper conduct — the payment itself is the offence.
  • Section 7 — Failure of commercial organisations to prevent bribery. A company or partnership commits this offence if an associated person bribes another on its behalf. This is strict liability: the prosecution does not need to prove the organisation knew about the bribe.

The Section 7 "Adequate Procedures" Defence

The only defence to a section 7 charge is that the organisation had adequate procedures in place. The Ministry of Justice guidance sets out six principles: proportionate procedures; top-level commitment; risk assessment; due diligence on third parties; communication and training; and monitoring and review. Running through all six in order is a structured and credible APC answer.

Corporate Hospitality and Facilitation Payments

Corporate hospitality is not automatically prohibited. The practical test is whether a fair-minded observer would conclude the hospitality was intended to induce improper conduct. Timing and value matter: premium match tickets offered by a contractor the week before a tender decision you are involved in should be declined and reported in your firm's gifts register, regardless of your personal intent.

Facilitation payments — small payments to expedite routine official processes — are illegal under UK law with no exception. Penalties are severe: unlimited fines for companies and up to ten years' imprisonment for individuals.