UK Law and Practice Contributed by: Neil Swift, Jasvinder Nakhwal, Charlotte Tregunna and Rachel Cook, Peters & Peters
• remediation, including disciplinary or structural reforms; • absence of prior misconduct; and • provision of transparent and timely financial infor - mation for sentencing. These factors may lead to non-prosecution, a DPA or reduced penalties. Aggravating Factors Aggravating factors include: • delayed or incomplete disclosure; • obstruction of investigation; • repeated or systemic misconduct; • involvement of senior management; and • failure to preserve evidence or co-operate. Public interest considerations also guide discretion, particularly where prosecution would be dispropor - tionate in minor, historic or isolated cases. 7.5 Recent Landmark Investigations or Decisions Several 2025 cases illustrate heightened enforcement intensity and cross-border co-ordination: • United Insurance Brokers Ltd (UIBL) – April 2025: SFO charged UIBL with failure to prevent bribery relating to reinsurance contracts in Ecuador. This is expected to be the first jury trial for a “failure to prevent bribery” offence. • Blu-3 and Mace Group – April 2025: There were co-ordinated SFO raids and arrests in the UK and Monaco concerning alleged bribery linked to a Dutch data centre project for Microsoft. This is indicative of the SFO’s new focus on rapid cross- border enforcement. • Entain (formerly GVC Holdings) – October 2025: Entain’s former executives were charged with brib - ery and fraud relating to Turkish operations. This follows a GBP585 million DPA concluded in 2023. • Glencore: These ongoing proceedings concern six former executives following the company’s GBP280 million fine in 2022. The Financial Report - ing Council opened an audit investigation in 2025, signalling continued scrutiny.
• Bennett Verby Ltd – August 2025: 2025 marks HMRC’s first prosecution for the “failure to prevent facilitation of tax evasion” offence, marking a more aggressive stance on economic crime enforce - ment. These cases collectively highlight a clear shift towards faster case progression, cross-agency collaboration and greater use of the “failure to prevent” model. 7.6 Level of Sanctions Imposed Sanctions for bribery and corruption offences vary according to the offender, the severity of the miscon - duct and the level of co-operation. Individuals convicted under Section 1, 2 or 6 of the BA 2010 face up to ten years’ imprisonment and/or an unlimited fine on indictment, and up to 12 months’ imprisonment on summary conviction (subject to Magistrates’ Court sentencing limits). In 2012, a court clerk at Redbridge Magistrates’ Court was the first person convicted under the BA 2010; he received a four-year custodial term (reduced on appeal from six years) for accepting a GBP500 bribe in return for diff Crown Court for corruption involving a council recycling-centre contract. The sentences included 28 months’, 22 months’ and 18 months’ impris - onment, with confiscation orders exceeding GBP365,000. • In April 2025, four individuals involved in a demoli - tion-industry corruption scheme (over GBP600,000 in bribes) were sentenced at Southwark Crown Court. Three received three and a half years’ imprisonment and one two years’ imprisonment. • In May 2025, a group of senior energy sector professionals were convicted following a CPS prosecution for bribery and money laundering. The convicted individuals received custodial sentences between two years five months’ and four years’ immediate imprisonment, while two received sus - pended sentences of 12 and 13 months. • In November 2025, the former leader of Reform UK in Wales was sentenced to ten and a half years’ manipulating court records. In more recent examples: • In 2023, five men were jailed at Car -
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