We have published the second briefing in a two-part series examining the intersection of artificial intelligence (AI) and legal professional privilege in the context of investigations. Part 1 in this series addressed: (i) a recap on key privilege principles and their interaction with generative AI tools; and (ii) privilege considerations arising in internal
enforcement & investigations
Ultra Electronics Deferred Prosecution Agreement: Five Key Points
The Serious Fraud Office (SFO) has entered into its first Deferred Prosecution Agreement (DPA) in five years. The agreement with Ultra Electronics Holdings Limited (Ultra), a British defence, security and aerospace manufacturer, covers historic alleged conduct relating to failure to prevent bribery under the UK Bribery Act 2010 (…
New briefing note: Whistleblowing – Key steps for regulated firms and individuals when considering and handling protected disclosures
Whistleblowing can take many different forms, can encompass a wide range of different concerns and can vary in terms of seriousness. However, there is at least one constant: knowing when to report and dealing with concerns raised both require careful handling and consideration if regulated firms and individuals are not to create additional problems for…
Notice in a nutshell update: FCA fines former chief executive and issues Primary Market Bulletin 62
At the start of this year, the Financial Conduct Authority (FCA) issued Final Notices against two former finance directors of Carillion plc (Carillion), Mr Adam and Mr Khan, in connection with misleading announcements, having reached a settlement with them ahead of the Upper Tribunal proceedings. We previously wrote about this development…
The New EU Anti-Corruptive Directive – What UK and Global Companies Need to Know.
On 21 April 2026, the EU Parliament adopted a new Anti-Corruption Directive, introducing a comprehensive anti-corruption criminal law to Member States with significant corporate penalties. The Directive reinforces cooperation with EU agencies and bodies including the European Anti-Fraud Office, the European Public Prosecutor’s Office, Europol and Eurojust, signalling a coordinated enforcement landscape for cross-border corruption…
New Notice in a Nutshell briefing: FCA prohibits chief executive of online trading firm from working in financial services due to lack of honesty and integrity

In March 2026 the Financial Conduct Authority (FCA) published a Final Notice in which it prohibited Kasim Garipoglu from working in financial services in the UK, on the basis that he was not fit and proper due to a lack of honesty and integrity and also because the FCA considered that he posed…
New UK law makes companies liable for criminal acts of senior managers: four key implications
The Crime and Policing Bill 2025 received Royal Assent on 29 April 2026, meaning organisations will be criminally liable where a senior manager commits any criminal offence in the UK while acting within their actual or apparent authority. This replaces and broadens the changes made by the Economic Crime and Corporate Transparency Act 2023…
New Notice in a Nutshell briefing: PRA fines U K Insurance Limited £10,625,000 in connection with solvency reporting

Last month the Prudential Regulation Authority (PRA) published a Final Notice imposing a financial penalty of £10,625,000 on U K Insurance Limited (UKI) in connection with a “double-counting” error which led to a miscalculation of UKI’s Solvency II balance sheet during 2023 and 2024 and consequently an overstating of its solvency…
New Notice in a Nutshell briefing: FCA fines Dinosaur Merchant Bank £338,000 for market abuse surveillance failures in its CFD business

On 24 March 2026, the Financial Conduct Authority issued a Final Notice to Dinosaur Merchant Bank Limited, imposing a financial penalty of £338,000 for failing to detect and report suspicious orders and transactions in its contract for difference business.
For the key takeaways from this case, as well as the key findings, please see our…
New briefing note: AI & Privilege: Part one, internal investigations – Key considerations for professional services and financial services firms
The rapid adoption of artificial intelligence (AI), particularly generative AI (GenAI), is transforming how professional services and financial services firms operate. We have published a new briefing note which is the first in a two-part series examining privilege and AI. In Part 1 we set out: (1) a recap on key…











