Module Application
Bribery and corruption can expose organisations and individuals to serious criminal, commercial and reputational consequences. This module applies to organisations carrying on business in Ireland, and to Irish organisations with overseas operations, where they or persons acting on their behalf may interact with public officials, customers, suppliers, intermediaries, agents, business partners or other third parties. It is particularly relevant where organisations engage in public procurement, lobbying, licensing, permitting, inspections, grants, regulated activities or cross-border business.
The module supports directors, senior management, compliance, legal, finance, procurement, HR and operational teams in implementing proportionate anti-corruption and bribery controls. It addresses the Irish criminal law framework, corporate liability and the reasonable-steps and due-diligence defence, as well as related requirements concerning lobbying, protected disclosures, procurement integrity and accurate records.
Module Scope
This module covers the principal anti-corruption and bribery obligations and control expectations applicable in Ireland. It addresses the identification and prevention of direct and indirect corruption risks, including risks arising through employees, officers, agents, subsidiaries, intermediaries and other business partners, and considers conduct occurring partly in Ireland or outside the State.
The scope includes governance, risk assessment, policies, training, monitoring, third-party due diligence, conflicts of interest, gifts and hospitality, donations and sponsorships, payment transparency, public-sector interactions, lobbying, procurement integrity, reporting and investigations. It also explains enforcement exposure, including corporate and officer liability, criminal penalties, seizure and forfeiture, procurement exclusion and protected-disclosure remedies. EU and international instruments are included as horizon-scanning or benchmarking material where relevant, rather than as standalone Irish criminal obligations unless implemented in Irish law.
Some of the specific questions this module covers are:
Does the organisation maintain proportionate anti-corruption and bribery controls that address its business model, public-sector touchpoints, jurisdictions, intermediaries and other third-party risks?
Does the organisation take all reasonable steps and exercise due diligence to prevent corruption offences by directors, officers, employees, agents and subsidiaries?
Does the organisation prohibit and control gifts, hospitality, expenses, donations, sponsorships, conflicts of interest and payments that could create improper influence or conceal corrupt conduct?
Does the organisation apply appropriate due diligence, contractual controls and monitoring to higher-risk third parties, subsidiaries, acquisitions, joint ventures and strategic relationships?
Where relevant, does the organisation meet its lobbying, public-procurement and public-official interaction requirements and manage the related integrity risks?
Does the organisation provide effective reporting, investigation, evidence-preservation, remediation and external-escalation processes for suspected bribery and corruption?
The key topics covered in this module are:
Legal Framework and Scope of anti-corruption and bribery in Ireland
Corporate Liability and Reasonable Steps Framework
Prohibit and Prevent Bribery and Corruption Offences
Gifts, Hospitality, Conflicts and Improper Advantages
Public Sector, Lobbying and Procurement Integrity
Speak Up, Reporting and Investigations
Enforcement, Penalties and Remediation Consequences
The module encompasses a range of legislative sources including:
Criminal Justice (Corruption Offences) Act 2018
Regulation of Lobbying Act 2015
Regulation of Lobbying and Oireachtas (Allowances to Members) (Amendment) Act 2023
Protected Disclosures Act 2014, as amended
Companies Act 2014
Criminal Justice Act 2011
European Union (Award of Public Authority Contracts) Regulations 2016
Relevant regulators and enforcement bodies include:
Department of Justice
An Garda Síochána, including the Garda National Economic Crime Bureau
Standards in Public Office Commission (SIPO)
Office of the Protected Disclosures Commissioner
Non-compliance can result in criminal prosecution, fines and imprisonment, corporate and officer liability, seizure and forfeiture of bribes or related property, public-office consequences, procurement exclusion or remedies, lobbying enforcement action and remedies for penalisation of protected reporting persons.
This module maps regulatory consequences to each obligation, including individual and corporate criminal liability, officer liability, fines, imprisonment, seizure and forfeiture, procurement exclusion, lobbying enforcement and protected-disclosure remedies.
Legal Framework and Scope
Criminal Justice (Corruption Offences) Act 2018, ss. 1-2, 5-13 and 17-18
Directive (EU) 2026/1021 on combatting corruption (Ireland transposition watchlist)
OECD Anti-Bribery Convention, United Nations Convention against Corruption and GRECO materials (benchmarking and context)
Corporate Liability and Reasonable Steps Framework
Criminal Justice (Corruption Offences) Act 2018, s. 18
Companies Act 2014, Part 5 (where directors duties and conflicts are relevant)
European Union (Award of Public Authority Contracts) Regulations 2016, reg. 24
Prohibit and Prevent Bribery and Corruption Offences
Criminal Justice (Corruption Offences) Act 2018, ss. 5-10 and 14-16
Companies Act 2014, ss. 281, 285 and 286
Gifts, Hospitality, Conflicts and Improper Advantages
Criminal Justice (Corruption Offences) Act 2018, ss. 5-8 and 14-16
European Union (Award of Public Authority Contracts) Regulations 2016, reg. 24
Public Sector, Lobbying and Procurement Integrity
Regulation of Lobbying Act 2015, ss. 5-6, 8, 12, 16 and 22
European Union (Award of Public Authority Contracts) Regulations 2016, regs. 18, 24 and 57
Speak Up, Reporting and Investigations
Protected Disclosures Act 2014, as amended, ss. 5-7A, 12, 14A and 16-16C
Criminal Justice Act 2011, s. 19
Criminal Justice (Corruption Offences) Act 2018, ss. 5-10 and 18
Enforcement, Penalties and Remediation Consequences
Criminal Justice (Corruption Offences) Act 2018, ss. 17-21
Regulation of Lobbying Act 2015, Part 4
European Union (Award of Public Authority Contracts) Regulations 2016, reg. 57
Protected Disclosures Act 2014, s. 14A
This module is designed for organisations operating in or from Ireland, including their directors, officers, employees, compliance and legal teams, procurement and finance functions, and those responsible for managing third parties, public-sector interactions, lobbying or investigations.