UK Trends and Developments Contributed by: Neil Swift, Jasvinder Nakhwal, Charlotte Tregunna and Rachel Cook, Peters & Peters
Firms that handle internal disclosures promptly and fairly will be better positioned to avoid escalation to regulators. UK–France–Switzerland Anti-Corruption Alliance In March 2025, the SFO, France’s Parquet National Financier and Switzerland’s Office of the Attorney General launched a new anti-corruption taskforce. The alliance is designed to strengthen investigative collaboration, share intelligence and co-ordinate cross-border cases. All three countries have far-reaching anti-bribery laws that allow prosecution of overseas conduct linked to their jurisdictions. The taskforce formalises long- standing co-operation and is expected to produce more joint investigations and parallel enforcement actions. For multinational businesses, this development under - scores the need for co-ordinated global compliance strategies. Jurisdictional boundaries are becoming less of a barrier to enforcement. Recent Enforcement and Case Developments Several cases this year illustrate the SFO’s active enforcement posture. • United Insurance Brokers: In April 2025, the SFO charged United Insurance Brokers Ltd with fail - ure to prevent bribery in connection with reinsur - ance contracts in Ecuador between 2013 and 2016. Intermediaries allegedly paid bribes to state officials in exchange for contracts worth USD38 million. If this proceeds to trial, it will be the first SFO failure-to-prevent-bribery case heard by a jury (in 2018, a dormant company was convicted following a contested CPS prosecution for Section 7 offences). • Blu-3 and Mace Group: Also in April 2025, the SFO conducted co-ordinated raids and arrests in the UK and Monaco concerning alleged bribery linked to the construction of a Dutch data centre for Microsoft. The investigation targets the UK com - pany Blu-3 and former associates of Mace Group. It demonstrates the SFO’s commitment to rapid cross-border action.
• Entain (formerly GVC): In October 2025, former executives of Entain appeared in court charged with bribery and fraud relating to gambling opera - tions in Turkey. The company had previously entered into a DPA with the CPS in 2023. The case illustrates that agencies beyond the SFO are increasingly willing to pursue complex bribery investigations and prosecutions. • Glencore: The 2022 Glencore prosecution remains a landmark, with a GBP280 million fine for bribery in Africa. The SFO has since charged six former executives, with a trial scheduled for 2027, and the Financial Reporting Council opened an audit investigation in 2025. These cases show that prosecutors are prioritising multi-jurisdictional co-ordination, corporate co-oper - ation and alternative charging strategies. Businesses should reassess third-party risk controls, remediation processes and early engagement protocols. Global and Multilateral Trends United States In February 2025, the White House paused most new Foreign Corrupt Practices Act cases for review. By June 2025, the Department of Justice had refocused its enforcement on cases with national security or competitiveness implications and strengthened incen - tives for voluntary self-reporting. Although enforce - ment has resumed, it is now more targeted. OECD The OECD’s March 2025 update on corporate anti- corruption compliance benchmarks covered gifts and hospitality, political contributions and the independ - ence of compliance functions. It found that only Can - ada and the EU currently require lobbyists to declare social media or awareness campaigns, a gap likely to lead to reform. These developments suggest a global trend towards convergence. Multinational companies should expect regulators to evaluate programmes not just against local law but against emerging international norms.
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