On 26 November 2025 the SFO published updated guidance on its evaluation of compliance programmes (the Guidance). The Guidance follows on from the updated Corporate Prosecution Guidance published in August (and which was covered in our recent horizon scan), the SFO corporate cooperation guidance published in April (see here), and the Home
Horizon Scanning: Investigations and Enforcement
Shifting geopolitical dynamics have seen a wave of changes across the international investigations and enforcement landscape. In this edition, we focus on some of the most significant of these changes – from the issue of new cooperation guidelines by the Serious Fraud Office (SFO) to the abandonment by the Financial Conduct Authority (
New co-operation guidance issued by the SFO
The SFO’s new cooperation guidance SFO Corporate Guidance – GOV.UK (published on 24 April) updates the SFO’s original cooperation guidance published in 2019 and comes ahead of the new failure to prevent fraud offence coming into force in September 2025 (see here: Failure to prevent fraud: What should you be doing before September? | Global
Failure to prevent fraud: what should you be doing before September?
With less than five months to go until the new UK failure to prevent fraud offence comes into force on 1 September 2025, many organisations are conducting risk assessments and enhancing anti-fraud policies and procedures with a view to preventing fraud and providing themselves with a defence should this be necessary.
The new offence will
Failure to Prevent Fraud – Risk Assessments
Introduction
On 6 November 2024 the UK government published its long-anticipated guidance on the failure to prevent fraud offence (the Guidance).
The new offence will come into force in September 2025. It will apply both to UK and to non-UK organisations, where there is some nexus to the UK. The only defence for an
UK financial crime enforcement: what lies ahead in 2022?
2021 was an extraordinary year in financial crime. In this blog we consider recent UK developments, the key issues emerging in 2022 and the practical implications for companies.
Taking a step back from these developments, we see four key overarching themes:
- An increased focus from authorities on the effectiveness of preventative systems and controls when