The AI recommended answer aligns with the conclusion of the discussion content, which suggests 'C' is the most accurate statement.

Reason for choosing this answer:
Option C states: "Even if an organization's anti-corruption program complies with the FCPA, it might not be sufficient for the purpose of complying with the UK Bribery Act." This statement is MOST ACCURATE because the UK Bribery Act (UKBA) is widely regarded as broader and stricter in its scope than the US Foreign Corrupt Practices Act (FCPA).
The key reasons for this broader scope include:

Coverage of Private Bribery: Unlike the FCPA, which primarily focuses on the bribery of foreign public officials, the UKBA prohibits bribery in both the public and private sectors (commercial bribery). This means an FCPA-compliant program might not adequately address private-to-private bribery scenarios covered by the UKBA's general bribery offenses (Sections 1 and 2).
No Exception for Facilitating Payments: The UKBA explicitly outlaws all "facilitating payments" (also known as "grease payments" or "expediting payments"), which are small payments made to speed up or secure routine governmental action. The FCPA has a narrow exception for such payments, although enforcement agencies discourage their use. The UKBA makes no such allowance, meaning a program permitting them, even in limited circumstances under the FCPA, would fail UKBA compliance.
Corporate Offense of Failure to Prevent Bribery: The UKBA introduced a distinct corporate offense under Section 7: "failure of commercial organisations to prevent bribery." A commercial organization can be held liable if a person associated with it bribes another person with the intent to obtain or retain business or an advantage for the organization, unless the organization can demonstrate it had "adequate procedures" in place to prevent such bribery. While the FCPA also imposes corporate liability, the specifics of the Section 7 offense and the "adequate procedures" defense often require a more comprehensive and proactive anti-bribery management system than might be strictly necessary for FCPA compliance alone.

Therefore, an anti-corruption program designed solely to meet the requirements of the FCPA might not be comprehensive enough to ensure full compliance with the UKBA, particularly concerning private sector corruption and the absolute prohibition on facilitating payments.

Reason for not choosing the other answers:

A. The UK Bribery Act only exercises jurisdiction over individuals and corporate entities for acts of corruption when the offense occurs outside the United Kingdom. This statement is inaccurate. The UK Bribery Act has broad extraterritorial jurisdiction, applying to UK citizens, residents, and companies anywhere in the world. However, it also applies to bribery offenses committed *within* the United Kingdom by anyone, regardless of their nationality or place of incorporation. Its jurisdiction is not limited to offenses occurring outside the UK.
B. Unlike the FCPA, the UK Bribery Act makes it a crime to bribe a foreign public official in connection with international business transactions. This statement is inaccurate and misleading. Both the FCPA and the UK Bribery Act make it a crime to bribe a foreign public official. The FCPA's anti-bribery provisions specifically target payments to foreign officials to obtain or retain business. The UK Bribery Act has a specific offense for bribing a foreign public official (Section 6) in addition to its general bribery offenses. The phrasing "Unlike the FCPA" incorrectly implies that the FCPA does not criminalize such acts.
D. Like the FCPA, the UK Bribery Act contains an explicit exception for facilitating payments. This statement is inaccurate. The UK Bribery Act explicitly *does not* contain any exception for facilitating payments; they are illegal under the Act. In contrast, the FCPA does have a narrow exception for "routine governmental action" (though it is narrowly interpreted and discouraged).

Citations

The Bribery Act 2010
https://www.legislation.gov.uk/ukpga/2010/23/contents
Bribery Act 2010: Guidance about procedures which commercial organisations can put in place to prevent persons associated with them from bribing (Ministry of Justice)
https://www.gov.uk/government/publications/bribery-act-2010-guidance
Key Differences Between the FCPA and UK Bribery Act 2010 (Transparency International UK)
https://www.transparency.org.uk/what-we-do/business-integrity/uk-bribery-act/key-differences-between-fcpa-and-uk-bribery-act-2010