Data Driven Compliance: Understanding the ECCTA and Its Impact with Jonathan Armstrong
10 For 10: Top Compliance Stories For the Week Ending, May 3, 2025
Daily Compliance News: April 30, 2025, The 4 AM Wake-Up Call Edition
Compliance into the Weeds: Global Anti-Corruption Leadership
Life with GDPR - The ABB Enforcement Action from a UK Perspective
Everything Compliance-Episode 57-the Airbus edition
This Week in FCPA-Episode 190, week ending January 31, 2020 – the What’s $4 Billion Between Friends edition
This Week in FCPA-Episode 58, the Declination Edition
Everything Compliance-Episode 12
FCPA Compliance Report-Episode 282-SCCE CEI Wrap-up, Part II
FCPA Compliance and Ethics Report-Episode 167-Mara Senn on the Top 10 Practices in a Cross-Border Investigation
When Nick Ephgrave QPM, director of the Serious Fraud Office, addressed a group of corporate leaders at Jones Day’s London Office in May 2025 about the UK’s Economic Crime and Corporate Transparency Act 2023 (“ECCTA” or “the...more
In a recent alert, we highlighted the United Kingdom (UK) benchmark manipulation cases of Tom Hayes and Carlo Palombo from 2015 and 2019, respectively. Hayes was the first banker to be jailed in the LIBOR scandal....more
Last week the United Kingdom’s Serious Fraud Office (SFO) announced that, as a result of the UK Supreme Court's decision in R v Hayes/Palombo, a number of convictions arising from allegations of manipulation of well-known key...more
On 11 August 2025, HM Revenue & Customs ("HMRC") initiated its first corporate prosecution under the failure to prevent the facilitation of tax evasion offence, which was introduced by the Criminal Finances Act 2017. Bennett...more
The Crown Prosecution Service (CPS) and the Serious Fraud Office (SFO) have jointly updated their Corporate Prosecutions Guidance (the Guidance), providing clarification on their expectations for organisations in relation to...more
In a strident judgment that expresses “concerns about the effectiveness of the criminal appeal system in England and Wales in confronting legal error”, the UK Supreme Court has unanimously allowed appeals by Tom Hayes and...more
On 18 August 2025, the UK’s Crown Prosecution Service (CPS) and the Serious Fraud Office (SFO) announced the updated version of the joint guidance in relation to the prosecution of corporate entities (the “Guidance”). The...more
The new strict liability corporate criminal offence of Failure to Prevent Fraud (FTPF) comes into effect in England and Wales on 1 September 2025. ...more
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
Welcome to Season 2 of the award-winning Data Driven Compliance. In this new season, we will look at the new Failure to Prevent Fraud offense. Join host Tom Fox as we explore this new law and how to comply with it through the...more
The enforcement environments in the US and UK are evolving at rapid pace. In the US, the Criminal Division of the Department of Justice (DOJ) issued a new White-Collar Enforcement Plan and several revised policy documents on...more
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
On 9 July 2025, part 1 of the Independent Review of the Criminal Courts, chaired by Sir Brian Leveson was published (the Report). Leveson was tasked by the UK Ministry of Justice with conducting a wide-ranging review of the...more
Corporate legal departments are busy. They face new privacy regulations, ever-shifting trade policies, developments in artificial intelligence, and an unending stream of breaking news. It is difficult to keep up, and lately,...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
We detail below some recent developments which track the transformation of the UK's fraud prevention landscape and what this means for companies. WHISTLEBLOWER INCENTIVISATION: A TRANSFORMATIVE TOOL...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 ("SFO") is in a robust, and collaborative, mood. Three months after jointly announcing the formation of a new International Anti-Corruption Prosecutorial Taskforce (the "Taskforce"), the UK's premier...more
On Tuesday (24 June 2025) the FCA published its Prescribed Person’s Annual Report on whistleblowing (“24/25 Report”), which covers reports received and acted on with during the period 1 April 2024 – 31 March 2025 (the “24/25...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 guidelines confirm that FCPA enforcement will continue but provide opportunities for foreign authorities to lead where US interests are not significantly impacted....more
In just a few months, the UK’s corporate criminal liability offence of Failure to Prevent Fraud (FTPF) comes into force. Modelled on the framework of the Failure to Prevent Bribery offence, FTPF imposes strict liability on...more
The UK SFO’s new guidance on corporate cooperation makes clear that a company must show cooperation if it is to be invited to enter into a Deferred Prosecution Agreement (DPA). No change there. So what’s different in the new...more
With much fanfare, the Serious Fraud Office has launched its refreshed guidance on Corporate Cooperation and Enforcement. The guidance coincides with several new powers the SFO is eager to use. Overall, the agency is...more
On 24 April 2025, the UK’s Serious Fraud Office ("SFO") launched its updated External Guidance on Corporate Co-operation and Enforcement in relation to Corporate Criminal Offending (“Corporate Guidance”), cementing a bold...more