When the UK government launched Economic Crime Plan 2 (ECP2) in March 2023, its ambitions were clear. Building on the first Plan, the 2023-26 strategy set out three overarching goals: to cut fraud; reduce money laundering and...more
9/5/2025
/ Anti-Fraud Provisions ,
Anti-Money Laundering ,
Asset Recovery ,
Corporate Liability ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Fraud ,
HMRC ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
UK ,
White Collar Crimes
The Crown Prosecution Service (CPS) and Serious Fraud Office (SFO) have overhauled their Corporate Prosecutions guidance – clarifying how prosecutors will handle charges, forum and case strategy going forward. The previous...more
The Insolvency Service (IS) has set out a bold five-year vision to become the UK's lead enforcement body for corporate and insolvency standards in its investigation and enforcement strategy paper for the period 2026–2031,...more
HMRC has reportedly brought its first-ever corporate prosecution under the failure to prevent the facilitation of tax evasion offence, almost eight years after the legislation was introduced in the Criminal Finances Act 2017....more
The recent conviction of London-based art dealer Oghenochuko Ojiri marks a watershed moment for financial crime enforcement in the UK's regulated sector. For the first time, a conviction has been secured under section 21A of...more
8/12/2025
/ Anti-Money Laundering ,
Art ,
Due Diligence ,
Enforcement Actions ,
Money Laundering ,
Popular ,
Risk Assessment ,
Sanctions ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing ,
UK
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
In our first article in this series, we explored the expanded mandatory and discretionary exclusion grounds under the Procurement Act 2023 (the "Act"). The Act doesn't just expand the grounds for exclusion. It also changes...more
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 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 Procurement Act 2023 (the "Act") introduces a more expansive and centralised exclusion regime. For compliance professionals, the implications are significant: exclusion can now arise from a broader range of conduct –...more
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
4/25/2025
/ Corporate Counsel ,
Corporate Crimes ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Fraud ,
Regulatory Reform ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
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
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
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
Thursday 13 October 2022 saw the second reading of the draft Economic Crime and Corporate Transparency Bill, containing a raft of different measures including new and expanded powers for Companies House, the SFO and the NCA....more
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
On 1 November 2021, the independent Committee on Standards in Public Life published a report recommending sweeping changes to lobbying rules in the UK. The Committee’s 103-page report contains resounding criticisms of the...more
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
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
8/12/2020
/ Corporate Misconduct ,
Corruption ,
Criminal Convictions ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Internal Controls ,
Public Contracts ,
Public Procurement Policies ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
The responsibility to "clean up" corrupt business practices in the developing world has more often than not fallen to foreign-based investors as opposed to the authorities in those countries....more