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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

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

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

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

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

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

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

Happy Birthday! Ten takeaways as we chart the tenth birthday of the UK Bribery Act

On 1 July 2021, the UK Bribery Act (the Act) – one of the world’s global bribery and corruption benchmark laws – turns 10. It’s been an eventful 10 years: the Serious Fraud Office (SFO), the Act’s primary enforcement agency,...more

The new Brexit deal: tougher times ahead for an already struggling SFO?

On 24 December 2020, the UK and the EU reached a new Trade and Cooperation Agreement. The deal, which came into force on 1 January 2021, has important implications for white collar crime enforcement across Europe, and in...more

UK SFO Publishes DPA Guidance: comparing and contrasting the approach of the U.S. DOJ to DPAs

The United Kingdom Serious Fraud Office (SFO) recently published comprehensive guidance on Deferred Prosecution Agreements (DPAs). Lisa Osofsky, Director of the SFO, stated, “Over the past six years, we at SFO have been...more

Not a silver bullet: public procurement lessons from the G4S DPA

On 17 July 2020, a three-year Deferred Prosecution Agreement (DPA) between the Serious Fraud Office (SFO) and G4S Care & Justice Services (UK) Ltd (G4S) was approved. This DPA is the second arising from fraudulent conduct in...more

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