UK proposals for a “British FBI” – what does this mean for white-collar enforcement?

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On 26 January 2026, the UK Government published a White Paper, From local to national: a new model for policing (the “White Paper”), setting out proposals to create a National Police Service (NPS) – widely characterised in the press as a ‘British FBI’ – as part of a wider overhaul of policing structures in England and Wales.

According to the White Paper, the concern is that the current policing model is too fragmented and not well suited to respond to the challenges of modern crime, which is increasingly digital, cross-border and complex. As such, the aspiration is that in focusing on counter-terror, serious and organised crime, and fraud, the NPS will help to address this issue. As part of this shift, we anticipate that there will be a greater degree of crossover in the investigation and enforcement of different types of offences.

In this post, we will seek to focus on the proposals most relevant to white collar crime, including fraud, money laundering, bribery and corruption, and highlight practical implications for organisations with UK touchpoints.

NPS as the leading investigative authority for fraud, economic crime, and cybercrime

Under the White Paper, the NPS will become the lead investigative authority for fraud, economic crime, and cybercrime, working with – and eventually absorbing – the National Crime Agency (NCA). The government expects this to improve alignment across national, regional and local priorities, with the press framing the reform as the creation of a ‘British FBI’. While safeguards are proposed to protect the NPS’s independence, critics have raised concerns about increased centralisation of power.

Changes to existing specialist infrastructure

The treatment of existing specialist capabilities remains unresolved. Units such as Report Fraud, currently housed within the City of London Police, may either transfer to the NPS or continue operating under its direction. The integration of the NCA into the NPS would also be significant for money laundering enforcement, potentially reshaping reporting structures and enabling closer coordination with other economic crime investigations, with similar implications being likely for bribery and corruption enforcement.

This blending and crossover in the investigation and enforcement of different types of economic crime is already visible through the introduction of the Failure to Prevent Fraud offence (FTPF) in September 2025, which may easily pair with other offences, including bribery, fraud and money laundering.

Investigatory capacity: national forensics and “Police.AI”

For white collar and financial crime investigations, enforcement outcomes often depend on the ability to collect, process and interpret large volumes of digital evidence (email, chat, cloud records, financial systems, mobile devices). The White Paper includes proposals on strengthening investigatory capacity through a national forensics capability and the creation of “Police.AI,” a centre for AI-driven policing.

Together, these measures are intended to reduce forensic backlogs and accelerate investigations, meaning organisations may be expected to respond more quickly to enforcement requests involving large volumes of digital evidence.

Next steps: what does this mean for businesses?

Although the “British FBI” proposal is primarily a policing structural reform, it could have material downstream effects on how fraud, money laundering, bribery and corruption matters are investigated and coordinated. In anticipation of these reforms, organisations should ensure that they are prepared for an expected uptick and increased efficiency in enforcement.

While the major part of the reforms is not expected to be in force until 2029, we suggest that organisations take steps early to ensure they are (i) vigilant of the ongoing risk of liability for existing offences, and (ii) prepared for any increase in the frequency or severity of investigations and enforcement. We recommend undertaking the following measures:

  • Re-testing fraud risk assessments and fraud controls;
  • Refreshing incident response playbooks for fraud and economic crime, including evidence preservation (devices, cloud accounts, chat platforms, eDiscovery readiness);
  • Reviewing AML escalation and SAR processes, including decision-making, documentation, and (where relevant) how and when to seek NCA consent/defence before proceeding with transactions;
  • Re-validating anti-bribery and corruption controls, noting the government’s stated direction of travel toward stronger enforcement; and
  • Monitoring the implementation of measures proposed in the White Paper, to ensure the business is aware of the current reporting channels and requirements.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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