The prevailing orthodoxy is that when a fiduciary accepts a bribe, they hold it on an ‘institutional’ constructive trust for their principal. Given that English law does not recognise the ‘remedial’ constructive trust, ‘constructive trusts’ as used herein refers to the ‘institutional’ constructive trust unless otherwise stated. Much of the academic and judicial discussion has focused on whether this should be so, or whether the principal’s claim for the bribe should merely be a personal one. These discussions are often confined purely to equitable doctrines. However, a fiduciary’s corruption is not only equity’s problem, but also the concern of the State.