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Justice recalibrated: What the Criminal Courts Review means for economic crime prosecution

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

Back in Business? What the DOJ’s FCPA reset means for the SFO and UK companies

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 SFO’s prevention partnership with UK PLC: Balancing collaboration and enforcement

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 EU’s proposed Anti-Corruption Directive. What does this mean for non-EU companies?

In this article, we look at the proposed Anti-Corruption Directive, its impact on companies incorporated outside the EU and how non-EU countries might respond if it is implemented, looking to Ukraine and the UK as case...more

UK Government updates guidance on modern slavery and supply chain transparency

The UK Home Office has published an updated version of Transparency in Supply Chains (TISC), A Practical Guide which provides guidance on how organisations should “comply with the letter and spirit” of corporate reporting...more

SFO's new self-reporting guidance: A new deal or a departure from justice?

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

The new enforcement avengers? The UK, France, and Switzerland enforcement Taskforce: Local regulators join forces against global...

The United Kingdom (UK), France, and Switzerland announced on 20 March 2025 that they have jointly launched the International Anti-Corruption Prosecutorial Taskforce to combat complex international white-collar crime. The...more

Global Bribery and Corruption Outlook 2025

As we welcome 2025, the year ahead promises to be a year of change. After more than 70 national elections in 2024, the dust hasn’t fully settled, not least in the United States, where President Trump has taken office for the...more

The clock is ticking - UK Government publishes guidance on new ‘failure to prevent fraud’ offence

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

11/14/2024  /  Bribery , Fraud , Transparency , UK

Litigation activism confirms the risks of money laundering liability in supply chains

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

UK SFO launches Strategy 2024-2029

On 18 April 2024, the SFO announced that it had launched its Strategy 2024-2029, setting out its direction, values, approach and goals over the next five years. A bold, victims-centred approach The Strategy can be found...more

Crack down on Environmental Crime: new Economic Crime Unit and water bonus ban

The Environment Agency has launched a new Economic Crime Unit to enhance its fight against financial crimes in the waste management sector. This move aims to bolster the agency's capabilities in conducting financial...more

New SFO Director promises a bolder, more pragmatic approach to the fight against economic crime

On 13 February 2024, Nick Ephgrave gave his first public speech as Director of the Serious Fraud Office, to a packed room of white collar lawyers and press at the Royal United Services Institute. The new Director was bold and...more

The EU's deforestation regulation: Why UK and US companies should be paying attention?

A new and expansive regulatory regime to tackle global deforestation is being introduced in the EU by the Deforestation Regulation. The Deforestation Regulation entered into force in June 2023 and will have far-reaching...more

Reforming the legal test for Corporate Criminal Liability in England – a panacea or a placebo?

It’s certainly true that the UK criminal authorities have been crying out for a shot in the arm in the form of legislative reform, but will changing the law really help the Serious Fraud Office ("SFO") achieve more corporate...more

Is the UK entering into a new age of corporate crime enforcement?

Companies operating in the UK – whether incorporated in the UK or simply carrying on a business in the UK are entering into a period of significant change in the way corporate crime is going to be investigated and prosecuted....more

UK government proposes long-awaited reform to the identification doctrine for economic crime offences

On 16 June 2023, the Government announced its proposed reforms to the “identification doctrine” for economic crime offences to be introduced in the Economic Crime and Corporate Transparency Bill. The reform will apply only to...more

Human rights due diligence moves apace with the EU Parliament expanded version of the proposed CSDDD

On 1 June 2023, the European Parliament adopted and put forward an amended version of the draft Corporate Sustainability Due Diligence Directive. It goes much further than the version proposed by the European Commission and...more

Corruption In The Telecoms Sector: Beware The Elephant In The Room

The corruption risks of the telecommunications sector are too often given cursory consideration as, historically, there has been a keener focus on the extractive and energy sectors. Those sectors are considered to have a much...more

ESG Market Alert – August 2022

In this alert, we provide a round-up of the latest developments in ESG for UK corporates. In this month’s ESG Market Alert, we cover: New UN guidance on how businesses should ensure respect for human rights in...more

New UN guidance on how businesses should ensure respect for human rights in conflict-affected areas

The risk of businesses becoming involved with, and potentially complicit in, grave human rights abuses is naturally higher in the context of armed conflicts and other situations of widespread violence. The UN Development...more

Corporate crime reform in the UK: Unambitious? Too ambitious? Or, just plain unrealistic?

The Law Commission, on 10 June 2022, published its long-awaited Options Paper on Corporate Criminal Liability, which detailed possible options for the reform of corporate criminal liability in England & Wales (the “Options...more

ESG Market Alert – March 2022

In this alert, we provide a round-up of the latest developments in ESG for UK corporates. In this month’s ESG Market Alert, we cover: The EU Commission’s proposal for a directive on ESG-related due diligence obligations for...more

Upcoming mandatory Human Rights and Environmental Due Diligence in Europe: EU Commission publishes Proposal

The European Commission released on 23 February 2022 the much-awaited proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence (the "Proposed Directive"). This text lays...more

Aerospace and Defense Insights: Bribery and Corruption Outlook 2022

Today’s world is increasingly divided between kleptocracies that benefit from corruption as well as financial crimes and governments committed to fighting those crimes. Despite aggressive anti-corruption enforcement in parts...more

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