UK Trends and Developments Contributed by: Neil Swift, Jasvinder Nakhwal, Charlotte Tregunna and Rachel Cook, Peters & Peters
• Parallel risks: Sanctions exposure may run along - side criminal investigation. • Due diligence and screening: Entities must ensure rigorous screening of counterparties, beneficial owners and intermediaries to avoid inadvertent dealings with designated persons. • Responding to Requests for Information: Proce - dures should ensure timely and accurate respons - es to OFSI’s information requests, with clear escalation paths and legal oversight. • Asset exposure: Assets (real estate, equities, accounts) may be frozen without notice once a designation is made. • Licensing strategy and legal challenge: Compa - nies might seek licences or, in rare cases, chal - lenge designations via ministerial review or judicial review, though successful outcomes are rare. Conclusion The UK’s anti-corruption landscape is evolving rap - idly. The widened corporate attribution test, the new “failure to prevent fraud” offence, the increased use of technology, closer international collaboration and greater transparency in ownership all point towards a more assertive and co-ordinated enforcement envi - ronment. Alongside these developments, the growing use of targeted financial sanctions adds a powerful new dimension. The government’s ability to impose asset freezes and restrictions on individuals or enti - ties involved in serious corruption gives enforcement agencies an additional lever, particularly in cases where criminal prosecution may be impractical or delayed.
For corporates, the message is clear. Compliance frameworks must be robust enough to meet the new statutory standards and flexible enough to accom - modate evolving regulatory expectations. Governance structures, reporting lines and delegation protocols should be reviewed to ensure clear accountabil - ity. Data management systems need to support fast and transparent responses to investigative requests, and whistle-blowing channels must be both trusted and effective. At the same time, businesses should integrate sanctions compliance into their broader anti-corruption risk management, ensuring thorough screening of counterparties and vigilance against inadvertent dealings with designated persons. In June 2025, the government announced over GBP8 million of investment into the SFO over the next three years. The extra funding, which is in addition to the GBP9.3 million of funding announced in the 2024 Budget, will be used to bolster SFO’s intelligence capabilities so it can proactively identify and progress the biggest and complex economic crimes. The direction of travel is unmistakable. The UK is moving towards faster, more co-ordinated and more technologically sophisticated enforcement, where criminal law, regulatory action and sanctions oper - ate in concert. Companies that demonstrate credible compliance, proactive co-operation and an authentic commitment to integrity will be best placed to navi - gate this new era of accountability and public scrutiny.
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