The SFO have taken down their guidance on corruption in relation to facilitation payments, self reporting and corporate hospitality under the Bribery Act 2010. Some legal pundits suggest this is likely to result in a more hard line approach to prosecutions anticipated after the departure of the previous director Richard Alderman. John Williams commented "Whilst I would expect the SFO under its new director David Green to adopt a more consistent approach to prosecutions within their difficult budget constraints I would not expect the guidance on the issues of facilitation payments and corporate hospitality to extend the reach of the criminal in relation to these two areas.The previous guidance was unclear and already sought to extend the ambit of the criminal law considerably beyond what had previously been the case in relation to facilitation payments and corporate hospitality. This resulted in numerous companies incurring considerable expense in terms of compliance and gave ammunition for criticism of of the authorities of excessive interference in business. I would expect the guidance to be clearer and to assist bona fide companies in having more certainty about their policies (and from having to spend excessive amounts on compliance issues). It will also be interesting to see how this new guidance is likely to impact on  investigations which are already underway and are being based on the previous guidance."