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 (
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
The FCA and OFSI clamp down on UK sanctions enforcement
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
Failure to Prevent Fraud: when is it coming into force and what should organisations be doing now?
- we expect the “reasonable
SFO sets out its 5 year strategy: what does this mean for companies?
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
Fit for purpose? The UK’s Treasury Committee scrutinises UK sanctions
- Economic sanctions are a critical weapon in resisting Russia’s war against Ukraine.
- Despite its own production of
How can UK legislation and the powers of UK regulatory authorities extend to international companies?
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
New EU Anti-Corruption Framework: what does this mean for multinationals and their compliance programmes?
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
The New Economic Crime Plan 2023 – 2026
On 30 March 2023, the UK Government published its Economic Crime Plan for 2023 – 2026 (the Plan), which sets out a number of measures intended to enhance the UK’s regulatory framework and strengthen its response to the threat of economic crime. The Plan makes clear the Government’s intention to rely increasingly on the