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New SFO Guidance Unlikely to Drive Increase in Self-Reporting of Corporate Wrongdoing

On April 24, 2025, the UK Serious Fraud Office (SFO) released new guidance to encourage companies to self-report suspected corporate wrongdoing. The guidance emphasises that prompt self-reporting combined with full...more

UK Serious Fraud Office Issues New Self-Reporting and Corporate Cooperation Guidance

On 24 April 2025, the UK Serious Fraud Office (SFO) issued new guidance to encourage companies to self-report suspected corporate wrongdoing.  The guidance states that self-reporting, combined with full cooperation with the...more

Law firm agrees to pay £465,000 for breaches of Russia sanctions

The UK Office of Financial Sanctions Implementation (OFSI) has imposed a penalty of £465,000 on the Moscow subsidiary of Herbert Smith Freehills (HSF) for breaches of UK financial sanctions imposed on Russia following the...more

Nick Ephgrave’s First Year as SFO Director

Nick Ephgrave QPM, the Director of the Serious Fraud Office (“SFO”), recently marked the end of his first year in office. Ephgrave has brought a renewed energy, sense of purpose and proactive approach to the SFO, opening six...more

Rewarding Whistleblowers Will Only be Effective as Part of a Wider Package of Reforms

Serious Fraud Office (SFO) Director Nick Ephgrave has consistently touted the benefits of offering financial rewards to whistleblowers. With the FCA also considering its position on financial incentivisation, and a supportive...more

New SFO Pre-Investigation Powers Come into Force

On 15 January 2024, legislation came into force that enhances the Serious Fraud Office’s (SFO) compulsory information-gathering powers and streamlines the investigative process whilst imposing fresh obligations on companies...more

SFO Director Nick Ephgrave: The First 100 Days

The new SFO Director, Nick Ephgrave QPM, marks his first 100 days in post this month after succeeding Lisa Osofsky in September 2023. Ephgrave has overseen a dynamic start to his tenure with the announcement of three new...more

White Collar Crime Year in Review

2023 has been a year of change at the SFO with a new Director, enhanced investigatory powers and new statutory regime that will make it easier to prosecute corporate criminal offenders. Dropped investigations and acquittals...more

The FCA’s Proactive Enforcement Approach Exacerbates Growing Case Backlog

On 20 July 2023, the UK Financial Conduct Authority (FCA) published its Annual Report and Accounts for the year ending March 2023 (the “Report”). The Report represents the first opportunity to assess progress made in the...more

Digital Assets Consultation Offers First Step In Regulation

The International Organization of Securities Commissions, or IOSCO, published a consultation report in May titled "Policy Recommendations for Crypto and Digital Asset Markets." Originally published by Law360 - July 11,...more

The Continued Restricted Use of Information Obtained via Mutual Legal Assistance Request

On 4 November 2022, in the case of FCA v Papadimitrakopoulos & Gryparis1 , the UK High Court reaffirmed the principle that information obtained via Mutual Legal Assistance (MLA) requests can only be used for the purpose for...more

How New Framework Could Ease EU-US Data Transfer Burden

On 25 March 2022, the European Commission and United States announced an agreement in principle on a new Trans-Atlantic Data Privacy Framework. If passed into law, the framework will facilitate the transfer of personal data...more

OECD Recommendation Encourages Demand Side Bribery Enforcement

On 9 December, to mark International Anti-Corruption Day, the OECD launched the snappily-named 2021 Recommendation for Further Combating Bribery of Foreign Public Officials in International Business Transactions (“the...more

Bribery Act 2010: Ten Years On

Ten years have passed since the introduction of the UK’s primary anti-corruption law, the Bribery Act 2010 (“the Act”). This article examines the extent to which the Act has lived up to its billing as the international “gold...more

Fresh inquiry into economic crime will push UK further towards expansion of ‘failure to prevent’ legislation

On 23 October, the Treasury Committee launched a further inquiry to review what progress has been made in combatting economic crime. While the inquiry is focused on the effectiveness of the existing anti-money laundering...more

European Court of Justice Rules US Privacy Shield Invalid

On 16 July 2020, the Court of Justice of the European Union (CJEU) issued a judgment in Data Protection Commissioner v Facebook Ireland Limited, Maximillian Schrems (Case C-311/18, “Schrems II”) ruling that the Privacy Shield...more

Penalising the Failure to Prevent Human Rights Abuses

While debate rumbles on over the extension of ‘failure to prevent’ offences into the broad spectrum of financial crime, including fraud and money laundering, some have called for their introduction into an altogether...more

Money laundering: Buyer secrecy in the London art market

The introduction of the Fifth Money Laundering Directive on the 10th January 2020 brought the art market into the fold of regulated sectors for anti-money laundering purposes. The new law, which amends the existing...more

I’m Dreaming of a White (Collar) Christmas: 2019 in Review

The year 2019 has been something of a mixed bag for the UK’s criminal and regulatory authorities. While the Serious Fraud Office (“SFO”) and Financial Conduct Authority (“FCA”) appear to have taken involuntary sabbaticals...more

SFO Director Highlights Difficulty of Securing Convictions

Director of the Serious Fraud Office Lisa Osofsky used her annual Cambridge Symposium speech to emphasise the importance of international and corporate co-operation, to issue a call to arms for greater legislative assistance...more

W.I.R.E Debates: Law Commission Proposals on Suspicious Activity Reporting

The UK Law Commission has published a report criticising existing anti-money laundering legislation and providing recommendations to improve the quality of Suspicious Activity Reports (SARs).  What should we make of these...more

SFO Director Attacks Privilege Ahead of Corporate Guidance on Cooperation

The Director of the UK Serious Fraud Office (SFO), Lisa Osofsky, has promised to provide companies with concrete guidance on cooperation with the SFO. Based on her recent comments, this guidance is likely to encourage...more

Did Tesco Act Too Hastily in Entering Into DPA Negotiations? (Serious Fraud Office v Tesco Stores Ltd)

What is the background to this DPA and why is it only now being published? On 29 October 2014, the SFO opened an investigation into Tesco Stores Ltd in relation to a suspected offence of false accounting, contrary to...more

Unexplained Wealth Orders: More Bark Than Bite (So Far)

The UK National Crime Agency (“NCA”) has successfully resisted a challenge to the issue of its first Unexplained Wealth Orders (“UWOs”). The victory comes shortly after the agency announced its intention to expand the use of...more

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