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Key Takeaways From the SFO’s New Corporate Guidance

The updated guidance puts a heavy emphasis on self-reporting and clarifies how corporates under investigation can earn cooperation credit from UK prosecutors....more

Recent Developments for UK PLCs - March 2025

On 6 February 2025, the House of Lords Financial Services Regulation Committee published a report titled “Naming and shaming: how not to regulate”....more

UK Supreme Court Ruling in El-Khouri: Defining the Territorial Boundaries of the Proceeds of Crime Act 2002

The ruling, which narrows the UK’s jurisdiction over money laundering offences, will impact how cross-border money laundering offences are prosecuted going forward....more

UK and European Considerations: President Trump Pauses FCPA Enforcement

The executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains. On February 10, 2025, President Trump issued an executive order titled “Pausing Foreign...more

Top Tips for Global Companies Preparing for the UK’s New “Failure to Prevent Fraud” Offence

Companies in the US and around the world should consider their potential for UK exposure and assess their compliance programmes in light of that risk. On 1 September 2025, the UK will implement a new corporate criminal...more

Litigation 2024 Year in Review and 2025 Outlook: A view of the landscape in Europe and the UK

Welcome to our Litigation 2024 Year in Review and 2025 Outlook. In this report, we examine the legal trends that have shaped the commercial landscape in Europe and the UK and explore how these developments are likely to...more

UK Government Publishes Guidance on “Failure to Prevent Fraud” Offence

Guidance clarifies the implementation date, scope, and application of landmark new corporate offence, and provides suggestions for fraud-prevention procedures. On 6 November 2024, the UK Home Office published...more

New Civil Monetary Penalty Regime for UK Trade Sanctions

The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 empower OTSI to enforce UK trade sanctions through civil monetary penalties, building on the role of OFSI, which has enforced UK financial...more

The EU’s Corporate Sustainability Due Diligence Directive - Obligations for Companies

On 5 July 2024, the final text of the Corporate Sustainability Due Diligence Directive (CSDDD) was entered into the Official Journal of the EU. The CSDDD will enter force on 25 July 2024. This marks the final key step in the...more

Failure to Prevent Fraud: Corporates Face New Criminal Offence Amid Accountability Crackdown

Enhanced SFO powers and promises of swifter action on economic crime underscore the importance of anti-fraud measures for corporates and M&A dealmakers. The UK government is cracking down on corporates turning a blind eye...more

UK Court of Appeal Rules NCA’s Refusal to Investigate Cotton Imports From Uyghur Region Unlawful

The ruling propels UK law enforcement to increase its investigative powers under POCA, and businesses to enhance their supply chain due diligence. On 27 June 2024, the UK Court of Appeal found that the National Crime...more

Former Aide to Madagascan President Sentenced for Soliciting Bribes From UK-Based Company

The sentencing of Romy Andrianarisoa, the first ever foreign public official to be convicted under the Bribery Act 2010, provides important takeaways. On 10 May 2024, Romy Andrianarisoa was sentenced to three-and-a-half...more

SFO Announces Ambitious Five-Year Plan

The Serious Fraud Office’s strategy for 2024 to 2029 indicates aspiration to be a more effective agency and to incentivise personnel. On 18 April 2024, the UK’s Serious Fraud Office (SFO) published an ambitious, albeit...more

New SFO Director Sets Tone for Tenure

Motivated by a “visceral reaction” to large-scale economic crime, Nick Ephgrave lays out vision for a bolder, more pragmatic, and more proactive agency. Whistleblowers, dawn raids, and cross-agency collaboration are all...more

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