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
On 17 November 2025, the Financial Conduct Authority (FCA) issued an update on the bond consolidated tape provider (CTP).
Following the FCA’s earlier announcement on the bond CTP, the FCA states that it has filed an application with the High Court, asking it to lift the suspension on the bond consolidated
On 23 October 2025, the Financial Conduct Authority (FCA) and the Payment Systems Regulator (PSR) (the regulators) jointly responded to the HM Treasury’s (HMT) consultation on consolidating the PSR’s functions.
Summary
The regulators explained that they welcome the proposal set out in HMT’s consultation that the FCA take
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
With less than five months to go until the new UK failure to prevent fraud offence comes into force on 1 September 2025, many organisations are conducting risk assessments and enhancing anti-fraud policies and procedures with a view to preventing fraud and providing themselves with a defence should this be necessary.
The new offence will
Speak up and other internal investigations are on the rise (see our article here) amid increasing scrutiny from the media, public, authorities and other stakeholders of how investigations are conducted. Indeed, in higher profile matters the way in which an investigation is conducted can receive as much attention as the underlying issues.
The recent
This is the second article in our series breaking down the steps that companies will need to take to put in place “reasonable procedures” to prevent fraud. Our first post, which focussed on how to conduct effective fraud risk assessments, can be found here.
This comes ahead of the new UK failure to
Many companies are currently considering what steps they need to take in relation to the new UK failure to prevent fraud offence (which is expected to come into force later this year or in early 2025).
By way of recap, a company will be liable for failing to prevent fraud by its associated persons (e.g.
Regardless of your position on whether cryptocurrency is a legitimate method of payment, you can’t deny its permeation into mainstream society recently. From donations to Ottawa “freedom” protests[1] to countries approving bitcoin as legal tender,[2] the use of cryptocurrency is emerging beyond the dark web.
But with use comes misuse. In 2021, there