The Crime and Policing Bill has now made it through the House of Lords committee, and the current version contains clause 213, which would make an organisation criminally liable where a senior manager commits any offence...more
2/23/2026
/ Compliance ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Governance ,
Corporate Liability ,
Corporate Misconduct ,
Criminal Liability ,
Criminal Prosecution ,
Enforcement Actions ,
New Legislation ,
Proposed Legislation ,
Regulatory Reform ,
Risk Management ,
UK ,
White Collar Crimes
The Serious Fraud Office has spent the past two years building pace, confidence and public credibility. But the announcement of the Director's retirement – followed closely by the imminent exit of senior prosecutors on...more
2/4/2026
/ Anti-Corruption ,
Bribery ,
Corporate Counsel ,
Corporate Misconduct ,
Criminal Prosecution ,
Enforcement ,
Enforcement Priorities ,
Financial Crimes ,
Fraud ,
Investigations ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
On 8 January 2026, the Serious Fraud Office (SFO) announced that it will return £400,000 to nine victims of a global email fraud dating back more than two decades. The move, achieved through a civil recovery order under the...more
1/21/2026
/ Asset Recovery ,
Cooperation ,
Cross-Border Transactions ,
Deferred Prosecution Agreements ,
Email ,
Enforcement Actions ,
Financial Crimes ,
Fraud ,
Proceeds of Crime Act 2002 (POCA) ,
Restitution ,
Serious Fraud Office (SFO) ,
Terrorist Financing Regulations ,
UK ,
White Collar Crimes
The government's recent announcement of sweeping criminal court reforms marks a shift from the proposals outlined in the Independent Review of the Criminal Courts published in June 2025. Both the Independent Review and the...more
12/16/2025
/ Appellate Courts ,
Constitutional Challenges ,
Criminal Justice Reform ,
Criminal Procedure ,
Due Process ,
Financial Crimes ,
Fraud ,
Jury Trial ,
Regulatory Agenda ,
Regulatory Reform ,
Sentencing ,
UK
There is a clear sense that the current UK Government wants to put criminal justice reform back on the agenda – and economic crime is a big part of that. Fraud and corruption plainly cost the UK economy huge sums, yet...more
Corporate finance firms (“CFFs”) are vital to the growth and success of the UK economy. They help businesses raise money by connecting them with investors or lenders. The nature of their business means that it is essential...more
11/24/2025
/ AML/CFT ,
Anti-Money Laundering ,
Compliance Monitoring ,
Customer Due Diligence (CDD) ,
Due Diligence ,
Financial Conduct Authority (FCA) ,
Investors ,
Money Laundering ,
Regulatory Oversight ,
Risk Management ,
UK
Fraud isn't standing still. As everyday digital tools become more powerful, they are also making some of the oldest scams faster and harder to spot. Fraud isn’t standing still As everyday digital tools become more powerful,...more
11/24/2025
/ Artificial Intelligence ,
Contract Terms ,
Cybersecurity ,
Data Security ,
Financial Crimes ,
Financial Services Industry ,
Fraud ,
Identity Fraud ,
Machine Learning ,
Risk Management ,
Supply Chain ,
Third-Party Service Provider
A new government survey published on 5 November 2025 shows that external fraud against UK businesses is both widespread and under-recognised, revealing a persistent gap between corporate controls and confidence in their...more
In this final article in our series on the Procurement Act 2023 (the Act), we turn to the new Debarment List – a centralised public register of suppliers who may be excluded from public procurement. Whilst the idea of a...more
When the UK government launched Economic Crime Plan 2 (ECP2) in March 2023, its ambitions were clear. Building on the first Plan, the 2023-26 strategy set out three overarching goals: to cut fraud; reduce money laundering and...more
9/5/2025
/ Anti-Fraud Provisions ,
Anti-Money Laundering ,
Asset Recovery ,
Corporate Liability ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Fraud ,
HMRC ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
UK ,
White Collar Crimes
The Crown Prosecution Service (CPS) and Serious Fraud Office (SFO) have overhauled their Corporate Prosecutions guidance – clarifying how prosecutors will handle charges, forum and case strategy going forward. The previous...more
On 10 July 2025, the UK raised the threshold below which certain regulated firms can perform acts that would otherwise constitute a money laundering offence. The new threshold is £3,000. This is the second rise in the...more
HMRC has reportedly brought its first-ever corporate prosecution under the failure to prevent the facilitation of tax evasion offence, almost eight years after the legislation was introduced in the Criminal Finances Act 2017....more
The recent conviction of London-based art dealer Oghenochuko Ojiri marks a watershed moment for financial crime enforcement in the UK's regulated sector. For the first time, a conviction has been secured under section 21A of...more
8/12/2025
/ Anti-Money Laundering ,
Art ,
Due Diligence ,
Enforcement Actions ,
Money Laundering ,
Popular ,
Risk Assessment ,
Sanctions ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing ,
UK
The publication of the Independent Review of the Criminal Courts in June 2025 marks a significant attempt to reshape the structure, governance and workload of England and Wales' criminal justice system. The Review has clear...more
The Financial Conduct Authority (“the FCA”) has published final guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes, which updates its Guidance issued in 2017 (“the 2017...more
In our first article in this series, we explored the expanded mandatory and discretionary exclusion grounds under the Procurement Act 2023 (the "Act"). The Act doesn't just expand the grounds for exclusion. It also changes...more
On 9 June 2025, the U.S. Department of Justice (DOJ) published revised guidance for the enforcement of the Foreign Corrupt Practices Act (FCPA). Much attention has been paid to the apparent “unpausing” of enforcement...more
The Serious Fraud Office’s evolving approach to corporate engagement took another step forward this month. On 12 June 2025, speaking at a London conference, the SFO’s Chief Investigator Michael Gallagher provided the...more
The Procurement Act 2023 (the "Act") introduces a more expansive and centralised exclusion regime. For compliance professionals, the implications are significant: exclusion can now arise from a broader range of conduct –...more
On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...more
4/25/2025
/ Corporate Counsel ,
Corporate Crimes ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Fraud ,
Regulatory Reform ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
On 16 December 2024, the FCA published a discussion paper (DP24/4) (the “Discussion Paper”) on admissions and disclosures and market abuse regimes for cryptoassets. This is part of a series of publications by the FCA (and the...more
The FCA has published its expectations on registered or regulated firms partnering with unregistered cryptoasset firms, which may be illegally promoting to UK consumers....more
On 1 September 2025, the corporate criminal offence of ‘failure to prevent fraud’ (“the Offence”), created by the Economic Crime and Corporate Transparency Act 2023 (“ECCTA”), will come into force. On 6 November 2024, the...more
On 27 June 2024, the Court of Appeal handed down judgment in World Uyghur Congress v National Crime Agency [2024] EWCA Civ 715. The challenge of a 2023 decision by the High Court was brought by World Uyghur Congress ("WUC")...more