Investigations and Enforcement

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

On 24 April 2025, the Serious Fraud Office (SFO) published new guidance for firms about self-reporting, co-operation and Deferred Prosecution Agreements (DPAs) – a timely development in light of the failure to prevent fraud offence coming into force on 1 September 2025, which the SFO has recently said it is looking

On 16 April 2025, the Financial Conduct Authority (FCA) published a speech entitled ‘Working together to deliver our enforcement priorities’, which was delivered by its joint executive director of enforcement and market oversight, Therese Chambers, at the Spring Conference of NYU’s Program on Corporate Compliance and Enforcement.

Key points covered in

Recent regulatory activity and enforcement outcomes have highlighted the obligations on auditors to make reports to regulators in certain circumstances.  Given the web of relevant provisions, the number of bodies potentially requiring notification, the client confidentiality overlay and the pressures to which busy professionals are subject, keeping track of who should say what to whom

On the same day as HM Treasury’s publication of an action plan setting out a ‘new approach’ to ensure regulators support growth, the Financial Conduct Authority (FCA) has sent a clear message to the financial services industry that it is prepared to tackle non-financial misconduct which it considers demonstrates a lack of integrity

FCA and PRA enforcement action covers a range of misconduct with recent outcomes including both retail and wholesale cases and findings in respect of matters as various as customer treatment, market abuse and risk management. The details of the breaches and the activity which gave rise to the issues may vary but a consistent theme

In our latest Global Regulation Tomorrow Plus podcast, Kevin Harnisch, Mark Highman, Katie Stephen and Hannah McAslan-Schaaf discuss the failure to prevent fraud offence under the UK’s Economic Crime and Corporate Transparency Act 2023, which comes into force on 1 September 2025, and how it might impact US firms.

Listen to the podcast here.

Following publication of the government’s guidance in November 2024 and ahead of the new offence coming into force on 1 September 2025, UK Finance has published guidance for the financial services sector on failure to prevent fraud (FtPF) which it says “should be taken into account by a supervisory or enforcement agency when