Jurisdiction(s):
United Kingdom

UK corporate enforcement shifts: SFO–DOJ collaboration, ECCTA 2023 ‘failure to prevent fraud’, whistleblowing reform and AI risks heighten pressure for proactive anti‑bribery and fraud compliance

Published on: 04 September 2025

Published by a Law360 reporter

Legal News

Article summary

The meeting followed closely after the DOJ released its new white-collar enforcement strategy in May 2025 and, in June 2025, respectively, its guidance on enforcing the Foreign Corrupt Practices Act (FCPA), underscoring the SFO’s revitalised drive for assertive corporate enforcement. That direction has been evident since Ephgrave assumed leadership of the SFO in September 2023, publicly pledging to accelerate investigations, and to cultivate influence and leverage through partnerships at home and abroad. Although the SFO and DOJ have long co-operated, the DOJ’s pronouncement suggests a further, welcome step towards Ephgrave’s aim for the SFO to become the preferred, default collaborator in practice. The manual explicitly envisages bringing in suitable foreign law enforcement bodies, including the SFO, at an early stage in investigations and matters touching US interests, where relevant. It instructs that, prior to opening a fresh FCPA case, US prosecutors should carefully assess in full at the outset whether such an authority could pursue the same alleged wrongdoing. How this will operate in practice remains uncertain and may merely avert duplicative, parallel probes, yet it could equally demand tight‑knit coordination between agencies...

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