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
Investigations and enforcement
New briefing note – ‘Tis the season to set the tone: FCA update on non‑financial misconduct and what firms should be doing now
In a written response to a request from the Treasury Select Committee, the FCA has provided an update on its programme of work to address non‑financial misconduct (NFM), making it clear that the firm and its managers may also be held responsible in the event of bad behaviour anywhere in the ranks.
With…
New briefing note: The Which? super-complaint to the FCA regarding home and travel insurance – an action plan for firms
In September 2025, the consumer advocacy group Which? submitted a super-complaint to the Financial Conduct Authority (FCA) setting out its concerns in relation to the poor outcomes it considers consumers are experiencing in the retail home insurance and retail travel insurance markets (the Complaint). On the basis of its research and investigations…
New whistleblowing checklist for in-house legal
Solicitors have a duty to report serious concerns or breaches of the Solicitors Regulation Authority (SRA) Codes of Conduct promptly. However, they also owe duties of confidentiality to their employer and communications to which they are party may be protected by legal professional privilege. As a result, it can be difficult to know…
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 (…
Guidance on information sharing measures in the Economic Crime and Corporate Transparency Act 2023 updated
On 3 October 2025, updated guidance was published regarding the information sharing measures in the Economic Crime and Corporate Transparency Act 2023 (ECCTA) (the Revised Guidance).
ECCTA allows the direct and indirect sharing of information between businesses in the anti-money laundering (AML) regulated sector in order to prevent, detect and…
New Notice in a Nutshell briefing: Individual lack of integrity and a reminder of the need for effective contemporaneous governance arrangements
On 22 July 2025, the Financial Conduct Authority (FCA) issued a Final Notice to Mr Alba, imposing a fine of £1,049,500 and prohibiting him in relation to the provision of false and misleading information to the FCA. For the key takeaways from this case, as well as the key findings, please see our…
New Notice in a Nutshell briefing: PRA fines reinsurer’s London branch after post-Brexit governance failings
On 28 July 2025, the Prudential Regulation Authority published a Final Notice in respect of the London branch of Barents Reinsurance S.A., imposing a fine of £1,785,000 for failing to organise and control its affairs responsibly and effectively, as well as governance and regulatory reporting failures for more than two years post Brexit. For the…
Economic Crime Plan 2 – outcomes progress report published
On 2 September 2025, the Home Office published its outcomes progress report on the Economic Crime Plan 2 (ECP2), which was published in March 2023 and set out how public and private sectors would cut economic crime, protect national security and support the UK’s economic growth. The report provides a summary of key…
Acting with skill, care and diligence – lessons learned for firms and senior managers from the Woodford decision notices
Woodford (a prohibition and a fine) and on the investment management firm he founded (a fine). Both Mr Woodford and the firm have referred the decisions to the Upper Tribunal. Key takeaways are set out below but for more details see our Notice in a Nutshell.
Although the decisions are made in the context of…