Corporate Crime

According to court filings by Ariel Armon, an acquitted defendant, dated 24 April 2026 and only released on 22 May 2026, an expert witness engaged by the SFO to support its bribery and corruption investigation enlisted a public official to channel improper payments to other officials in order to secure information and materials for the SFO’s inquiry. In February 2026, the SFO halted its case against Graeme Hossie, the former chief executive of London Mining, Rachel Rhodes, its ex-chief financial officer, and Armon, a former consultant. The agency has rejected any suggestion of misconduct. The trio had been charged by the SFO in June 2023 with conspiring to pay bribes to state officials and intermediaries to advance London Mining’s interests in Sierra Leone. Hossie, Rhodes, and Armon were scheduled for trial in April 2026. However, the SFO discontinued the...

New tool for sentencers in the Crown Court The Sentencing Council has released a streamlined edition of the SentencingACE tool, created to assist sentencers in the Crown Court in identifying the relevant statutory provisions and sentencing guidelines when passing sentence for an offence. Access the tool here......

In this issue: Criminal liability Criminal procedure and evidence Proceeds of crime Bribery, corruption, sanctions and export controls Cybercrime and data protection offences Environmental offences Fraud, forgery, tax and theft offences Health and safety and corporate manslaughter offences Insolvency offences and Companies Act offences Local authority prosecutions International Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Criminal liability Corporate criminal liability expansion-the Crime and Policing Act 2026 The Crime and Policing Act 2026 (CPA 2026) has now secured Royal Assent, heralding a substantial reset of corporate criminal liability in the UK. By broadening attribution through a widened ‘senior manager’ test, it steps away from the restrictive bounds of the traditional identification principle. From 29 June 2026, corporate criminal exposure will depend not on fixing misconduct to the board or the most senior executives, but on the real-world allocation and exercise of decision-making authority throughout the organisation......

Reform of anti-social behaviour powers (2014) The Anti-social Behaviour, Crime and Policing Act 2014 (ABCPA 2014) overhauled the measures for tackling anti-social behaviour (ASB), seeking to bring remedies together and make their use simpler and more effective. In July 2014, the government released fresh statutory guidance, ‘Reform of anti-social behaviour powers: statutory guidance for frontline professionals’. That guidance was refreshed in August 2019 and again in January 2021 to incorporate the Sentencing Code, introduced by the Sentencing Act 2020 (SA 2020), which repealed and replaced ABCPA 2014, Pt 2, and it has been updated regularly since. The opening section of the statutory guidance prioritises victims, placing them at the heart of the response to ASB. Across the document there is a strong focus on ensuring the powers are deployed properly and in proportion to the particular conduct creating harm or nuisance. In July 2022, the Home...

This Practice Note explains how third-party material can be identified and obtained. It addresses investigators’ obligations under the Criminal Procedure and Investigations Act 1996 (CPIA 1996) and its Code of Practice to pursue all reasonable lines of enquiry, together with the disclosure responsibilities of Crown servants. It sets out how to seek disclosure directly from a third party and how to apply for a witness summons requiring production of material under the Criminal Procedure Rules 2025 (CrimPR 2025), SI 2025/909. The CPIA 1996 governs the prosecution’s disclosure in criminal proceedings, imposing primary, secondary and continuing duties in relation to material that could reasonably be considered to weaken the prosecution case or assist the accused. A parallel duty also exists at common law. For further detail, see Practice Note: Obtaining disclosure of unused evidence. Third party material refers to material held by a person,...

This Practice Note monitors the advancement of government bills pertinent to corporate crime that have been introduced in the House of Commons or the House of Lords within the UK across 2026 during the parliamentary year. It additionally supplies links to more details on each statute as enacted. For insight into significant secondary legislation, consultations, and other notable developments that might be of interest to corporate crime practitioners in 2026, consult Practice Note: Corporate Crime horizon scanner—2026. His Majesty, King Charles III, outlined the government’s priorities and intended policies for the forthcoming parliamentary session during the State Opening of Parliament on 13 May 2026, emphasising the modernisation of the criminal justice system, boosting court capacity, and enhancing the protection of the public. Core to this are the carried-over Courts Modernisation Bill, formally titled the Courts and Tribunals Bill, and Public Office...

1 Introduction 1.1 Bribery and corruption persist as significant problems in global commerce, notwithstanding numerous targeted initiatives to deter them. They inflict serious harm on communities where they arise. They: 1.1.1 divert funds and other assets away from those most in need; 1.1.2 impede economic and social progress; 1.1.3 harm enterprise, notably by pushing up the price of goods and services. 1.2 Our statutory duties are chiefly set by the Bribery Act 2010 (BA 2010). BA 2010 applies to us as a UK organisation if bribery happens anywhere within our operations. 1.3 We conduct our business [ es ] with integrity, and in a frank and principled way. Each of us must act to ensure [ insert organisation’s name ] stays free from bribery or corruption. 1.4 This policy is central to that aim. It is fully endorsed by the [ insert, eg Board ]. It...

To: [ name ] of [ address ] Please note that: The [ name ] [ District ] [ Borough ] [ City ] Council (the Council) is satisfied that a statutory nuisance [ exists OR is likely to [ occur OR recur ] ] under section 79(1) [ specify which subsection ] of the Environmental Protection Act 1990 (EPA 1990), originating from [ the premises at ] [ specify the address of the source of the nuisance ] and resulting from [ describe the matters which are causing the nuisance ]. This abatement notice is issued to you as you are [ the person responsible for the statutory nuisance OR [ the owner OR the occupier of ] the premises ]. What you are required to do [ You are required to abate... ...

As you may know, the Company is presently [ under investigation by the [ insert name of agency ] OR undertaking an internal investigation ] concerning [ insert allegations of fraud, bribery ]. [ External solicitors have been instructed to support the inquiry. ] This inquiry is strictly confidential, and we request that you preserve that confidentiality at all times and without exception. I ask that you attend a meeting with our legal team on [ insert date ] as scheduled. We consider that you may hold information that could aid our understanding of the facts connected to the issues under review and help clarify points further. Our wish to speak with you does not indicate that you are the subject of the investigation. Attending this meeting accords with your employment obligations, and we expect your full co‑operation in this respect. This letter sets out...

General principles—privilege and confidentiality One of the trickier problems a practitioner encounters during litigation, especially at the disclosure stage of proceedings, is protecting a client’s confidential documents and information from review by other parties and from being put before the court. A principal way to secure protection for material relevant to a dispute is to assert that it is privileged. Once it is established that a document is privileged, the holder acquires a right to refuse inspection of that document. For wider guidance on the meaning and effects of privilege, see Practice Note: Privilege—general principles. Crucially, merely labelling a document ‘privileged’ does not settle its status. To benefit from this special protection—allowing a client to maintain confidentiality and withhold inspection of a relevant document—the criteria for one of the recognised forms of privilege must actually be satisfied (see below). More generally, for a claim to...

In England and Wales, local authorities are treated as public, not private, prosecutors. This status stems chiefly from their prosecuting powers expressly arising under statutory provisions in law. Specifically, section 222 of the Local Government Act 1972 (LGA 1972) furnishes them with authority to prosecute......

On 23 October 2020, Nesil Caliskan, Chair of the Local Government Association’s (LGA) Safer and Stronger Communities Board, issued remarks about the powers councils require to curb the transmission of coronavirus (COVID-19). Caliskan argued that local authorities should be able to take “rapid action” against businesses that do not put in place appropriate safety measures, adding that he “look[s] forward to hearing more details…over the coming days”. See: LGA seeks tools to combat businesses violating safety measures amid coronavirus (COVID-19)—LNB News 23/10/2020 86. The interventions designed to limit the spread of coronavirus continue to change as government policy tracks how the virus is circulating within communities. To streamline arrangements, a three-tier set of response levels was brought in to manage localised transmission of coronavirus. These regulations took effect in England on 14 October 2020, establishing a three-tier framework of...