As 2026 begins, the UK is sharpening its concentrate on bribery, fraud and anti-money laundering (AML). The Severe Fraud Workplace (SFO) has launched new steering for companies on figuring out international bribery indicators, together with up to date steering on company cooperation. As well as, the federal government has revealed its UK Anti-Corruption Technique 2025, outlining its method to tackling corruption each within the UK and abroad.
SFO publishes international bribery indicators
As a part of the Worldwide Overseas Bribery Taskforce (IFBT), the SFO has launched steering geared toward serving to companies determine and deal with potential situations of international bribery. The IFBT, which incorporates businesses such because the SFO and Nationwide Crime Company (NCA) within the UK, in addition to legislation enforcement our bodies throughout the 5 Eyes nations, has developed a standard framework that attracts on its collective expertise of coping with international bribery instances.
The steering identifies six key classes of bribery threat:
- Conduct – Use of third-party brokers, consultants, and shell corporations.
- Authorities affiliations – Involvement with international authorities contracts or the necessity for international authorities permits or approvals.
- Nation hyperlinks – Connections to international locations with a low Corruption Notion Index or the place the enterprise has no actual connection.
- Possession – Property possession through trusts or cryptocurrency.
- Registration data – Deceptive enterprise descriptions or charitable registration anomalies.
- Different associations – Hyperlinks to politically uncovered individuals (PEPs) or people with wealth far exceeding their public service wage.
Whereas these indicators aren’t essentially indicative of felony exercise, the steering encourages companies to evaluate the chance profiles of people and corporations in high-risk sectors, and to take motion the place mandatory. Compliance professionals and companies are inspired to assessment their present programmes and improve them the place acceptable.
The shift in the direction of early detection and prevention of financial crimes is turning into extra outstanding, with a better concentrate on figuring out pink flags earlier than points escalate.
UK Anti-Corruption Technique 2025
The UK authorities’s Anti-Corruption Technique 2025 outlines its method to tackling corruption domestically and globally. The technique is constructed round three important pillars: combating corrupt actors, addressing UK vulnerabilities, and strengthening international resilience.
Key parts of the technique embody:
- Stronger enforcement – The UK authorities plans to ramp up enforcement motion towards corruption, together with reforms to the AML/CTF supervisory system. Skilled companies supervision can be consolidated underneath the Monetary Conduct Authority (FCA), a transfer that can create a extra cohesive and efficient framework for addressing corruption.
- Whistleblowing reforms – The federal government is exploring reforms to the whistleblowing framework, probably together with monetary incentives to encourage reporting of corrupt practices.
- Worldwide cooperation – The technique outlines the creation of a brand new SFO-led worldwide anti-corruption prosecutorial taskforce, which can improve cross-border cooperation in investigating corruption instances.
- Fraud and AML methods – The federal government has dedicated to publishing new methods centered on fraud prevention and asset restoration, in addition to addressing rising dangers within the AML area.
Whereas the technique will not be an entire overhaul of the UK’s anti-corruption framework, it makes an attempt to drag collectively current legal guidelines and initiatives right into a single narrative, fill some apparent gaps, and sign political intent. The federal government’s message is evident: the trail to enchancment lies primarily in higher enforcement, stronger supervision, and extra coordinated oversight, moderately than a wave of latest legislative duties.
SFO publishes company cooperation steering
In a separate transfer, the SFO has launched an up to date steering doc detailing the way it will consider company compliance programmes. It is a essential doc for organisations seeking to perceive how their compliance measures can be assessed throughout investigations, prosecutions, and eligibility for deferred prosecution agreements (DPAs).
The up to date steering stresses that the SFO will place specific concentrate on the Failure to Forestall Fraud offence, which got here into power in September 2025 underneath the Financial Crime and Company Transparency Act. This new offence makes companies criminally liable in the event that they fail to forestall fraud, and the SFO can be prioritising enforcement on this space.
The SFO’s up to date steering additionally highlights the rising use of synthetic intelligence (AI) and machine studying to hurry up investigations and enhance effectivity within the combat towards financial crime.
What companies ought to do now
Evaluate and strengthen compliance programmes: Whereas no new legal guidelines are being launched, companies ought to guarantee their present anti-corruption insurance policies align with the federal government’s concentrate on enforcement. Evaluate your procedures for detecting and stopping bribery, fraud, and cash laundering, guaranteeing they’re sturdy and actively monitored.
Improve inside controls and reporting programs: Strengthening inside reporting programs for whistleblowers is essential, as the federal government could incentivise reporting by means of reforms. Be sure that your workers have clear, confidential channels for reporting issues.
Refresh coaching and communications: Replace anti-bribery, fraud and AML coaching so it displays present enforcement expectations and real-world pink flags, together with third events, high-risk jurisdictions, and reporting obligations. Reinforce this with common supervisor briefings and focused coaching for higher-risk groups (gross sales, procurement, finance, and worldwide operations).
Keep up to date on enforcement developments: With a renewed concentrate on enforcement, companies ought to pay attention to the elevated scrutiny from businesses just like the Severe Fraud Workplace (SFO) and Nationwide Crime Company (NCA). Guarantee your small business is ready for extra rigorous investigations and that your data are prepared for inspection.
Collaborate with regulatory our bodies: The technique emphasises stronger coordination between legislation enforcement and companies. Proactively have interaction with regulators and compliance consultants to remain knowledgeable on finest practices and regulatory expectations.
Put together for ongoing scrutiny: The technique’s concentrate on enhanced supervision means companies should be ready for extra frequent audits and assessments of their anti-corruption measures. Recurrently audit your anti-corruption frameworks to make sure they meet evolving expectations.
