Formation of new anti-corruption alliance in Europe and what it means for international enforcement
On 20 March 2025, the UK Serious Fraud Office (SFO), French Parquet National Financier (PNF) and the Office of the Attorney General of Switzerland (OAG) announced the formation of a new taskforce to tackle international bribery and corruption. The “International Anti-Corruption Prosecutorial Taskforce” may be a decisive move to distinguish European anti-corruption enforcement and step into the territory recently vacated by the United States.
In this article, we examine the background and the expectations arising from this, in the context of the SFO’s approach to international enforcement. We also consider the wider context, including the impact of the Trump administration’s de-prioritisation of international bribery cases. Lastly, we look at cooperation between European authorities to date, in particular the landmark cooperation between the SFO and PNF in one of the largest bribery settlement to date, secured in January 2020 with Airbus SE, the French-headquartered, multinational aerospace and defence company.
The formation of this Taskforce marks the alignment of UK and European enforcement authorities, and potentially the assumption by the SFO of the leading role in pursuing international bribery and corruption. The SFO, PNF and OAG have expressly invited other authorities to join them in the Taskforce. Which authorities do, and if so how quickly, remains to be seen.
Assessing the SFO’s strategy
In April 2024, the SFO published “SFO Strategy 2024-29.” It sets out the SFO’s ambition to be the pre-eminent specialist, innovative and collaborative enforcement agency. Core objectives include strengthening its workforce and harnessing new technology.
A further objective is for the SFO to become the “partner of choice,” both nationally and internationally. The SFO has well-established links with other enforcement agencies around the world, and various powers to collaborate and share information. The SFO enforces various criminal offences with broad international reach and so it requires close and active partners around the world to assist with its investigations. Extraterritorial laws include the failure to prevent bribery under the Bribery Act 2010 and the failure to prevent the facilitation of UK or foreign tax evasion under the Criminal Finances Act 2017. From September this year, the Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduces a further offence of the failure to prevent fraud. These acts can capture organisations based overseas and the SFO will likely call on its international partners to assist it in obtaining relevant information.
We have seen an increase in the SFO’s capabilities and activities under the new Director, Nick Ephgrave QPM. The SFO recently received a funding boost of £9.3 million, bringing its budget up to £88.9 million for 2025-2026. The Director has expressed his intention to revive corporate cooperation and encourage companies to proactively inform the SFO about wrongdoing within their organisations. The SFO is currently updating its guidance to corporates on what cooperation means, including self-reporting, deferred prosecution agreements (DPAs) and compliance programmes, and expects to publish the guidance sometime this year. The ECCTA has also expanded the “identification doctrine,” the test for establishing a corporate’s liability for a range of criminal offences, establishing that if a “senior manager” acting within the actual or apparent scope of their authority commits a relevant offence, the organisation will also be guilty of the offence.
The Director has strongly advocated for rewards for whistleblowers, and in his Foreword to the SFO’s “Business Plan 2025-26,” published on 3 April 2025, the Director confirmed that the SFO will be “pushing for new initiatives such as progressing whistleblower incentivisation reform.”
Impact of the Trump administration
The timing of the announcement of the new Taskforce is highly significant. The US Department of Justice (DOJ) has historically taken a leading role in enforcing against international bribery and corruption under the Foreign Corrupt Practices Act of 1977 (FCPA), which has expansive territorial reach. But the US President, in the first few weeks of his second term, issued an executive order pausing FCPA enforcement activity for 180 days.
The President’s decision and the apparent shift in focus of the US administration could encourage the SFO to fill the gap left by the DOJ through enforcement of the similarly far-reaching, extra-territorial Bribery Act. The SFO Director has stated the Taskforce was “in no way a reaction to” the pause in FCPA enforcement. It is likely that preparatory work has been underway for some time, but the accident of the timing is striking. The repercussions of the FCPA pause for the fight against international bribery and corruption may invigorate the SFO, PNF and OAG to pursue more investigations under their new collaborative framework.
Will the SFO emerge as the global enforcement leader for countering international bribery? The SFO’s focus on becoming the preeminent enforcement authority, coupled with its well-established international cooperation objectives, makes this a clear possibility. The Taskforce certainly seems to be immediate proof of its ambition. “Through strong international partnerships,” affirmed Lucy Rigby KC MP, Solicitor General of the UK, “we will be able to robustly tackle cross-border economic crime and protect our future prosperity.”
Anticipated role of the Taskforce
The formation of the Taskforce follows significant cooperation between the three countries for over a decade. By bringing together their knowledge, experience and expertise in a formal framework, the expectation is that the Taskforce will facilitate the authorities to more actively pursue international bribery and corruption cases.
The Founding Statement of the Taskforce records the five key principles underlying its purpose. The authorities confirm their recognition of the significant threat of bribery and corruption and the severe harm that it causes, underscoring their commitment to tackling the threat within national and international legal frameworks. The authorities note their appreciation that the threat of bribery and corruption is complex and international in nature, and therefore success in combatting it “relies on us working closely and effectively together and building further on our strong existing relationships.”
The authorities confirm their intention to strengthen their collective effort by identifying four key deliverables: (i) a Leaders’ Group focused on the regular exchange of insight and strategy; (ii) a Working Group, for the purpose of devising proposals for cooperation on cases; (iii) increased best practice sharing to make full use of the authorities’ combined expertise; and (iv) a strengthened foundation for seizing opportunities for operational collaboration.
Lastly, the authorities extend an invitation to other “like-minded” agencies involved in tackling international bribery and corruption to join the Taskforce, raising the prospect of additional enforcement agencies becoming part of the Taskforce in the future.
The Airbus Jetstream: prior cooperation between the UK and France
The SFO and PNF have a track record of effective cooperation on bribery cases, notably the Airbus settlement. In January 2020, following a four-year global investigation, Airbus reached a US$4 billion same-day settlement with the SFO, PNF, DOJ and US Department of State. This groundbreaking settlement, at the time the largest ever anti-corruption settlement, was also the first concluded jointly by the SFO under a DPA and by the PNF under the French equivalent, convention judiciaire d'intérêt public (CJIP), along with parallel settlements with the US authorities.
Until CJIPs came into force in December 2016, France had no history of incentivising organisations to cooperate with enforcement investigations. The Airbus settlement marked a sea-change in French enforcement, and the close partnership with the SFO and DOJ was integral to this. The PNF noted in its press release: “The PNF, SFO and the US authorities coordinated their actions to ensure the simultaneous signatures of a CJIP and two DPAs with Airbus … This new stride in the fight against international corruption is the fruit of work carried out by the PNF with the trust and complete cooperation of the SFO, DOJ and the Federal Prosecutor of the District of Columbia.” The then-SFO Director, Lisa Osofsky, emphasised the importance of international cooperation to the settlement. “A resolution of this scope would not have been possible without the commitment, determination and hard work of SFO staff and our French and American colleagues,” she explained.
Will we see the SFO, PNF and OAG focusing on reaching settlements with European organisations over bribery? Both the SFO and PNF have expressed the importance of encouraging corporate cooperation. Shortly prior to the announcement of the Taskforce, in November 2024, the SFO announced that it had launched an investigation into suspected bribery and corruption at Thales, a multinational aviation and defence electronics group headquartered in France with a subsidiary in the UK. The SFO and PNF are conducting a joint investigation, as they did with respect to Airbus. “Working collaboratively with our international partners,” the SFO Director emphasised, “is a crucial factor in the fight against international corruption and with this case I hope to reinforce the SFO and PNF’s long-standing relationship, built on mutual cooperation and shared success.”
With this reinvigoration of European enforcement activity, international companies operating in Europe will need to ensure they have effective corporate governance measures and robust compliance programmes to guard against bribery risks.
