In the next instalment of our global horizon series (first instalment available here), our team observes a growing trend of increased international collaboration between regulators in different jurisdictions despite wider geopolitical tensions.
Europe
The European Public Prosecutor’s Office (EPPO), the independent public prosecution office of the European Union has become increasingly active. It is
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
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 (
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
The resolution of two sanctions-related investigations over the last month by both the Financial Conduct Authority (FCA) and the Office of Financial Sanctions Implementation (OFSI) could signal the start of the anticipated increase in UK enforcement in respect of failings relating to financial sanctions systems and controls (in the case of
The SFO has published its 5-year strategy document (the Strategy Document), highlighting a number of areas of focus, from international coordination with counterparts to capitalising on technology and incentivising their workforce.
This follows Director of the SFO, Nick Ephgrave’s, speech in February 2024 setting out key priorities (see our recent Investigations and Enforcement horizon
Summary
There has been a recent trend of greater regulatory enforcement for international companies that “carry on a business (or part of a business) in the UK”. We have set out in this article the relevant UK legislation and authorities that can enforce against international companies, with a particular focus on how these
Summary
As part of a new anti-corruption package announced on 3 May 2023, the European Commission has proposed a new directive (Directive) which, if implemented, would require EU member states (Member States) to meet common standards in their anti-corruption legislation.
More detail on the EU’s anti-corruption package, including the proposed new