US-style corporate bribery plea bargain deals, such as the one offered to BAE Systems, risk being undermined by European Union anti-corruption rules, according to a document circulated among ministers.

A letter from Jack Straw, justice secretary, said businesses told him a law banning companies convicted of corruption from lucrative EU public work contracts is “chilling” efforts to persuade British multinationals to admit wrongdoing in return for more lenient treatment.