Legal News

As part of Chancellor Rachel Reeves’ recent government spending review, the government has pledged an extra £8.3m in additional support to the SFO over the coming three financial years. This will lift the specialist prosecutor’s budget up to £97.64m by 2028 in total. The money will target proactive intelligence activity, bolster its proceeds of crime team, and improve the effective use of advanced technology in disclosure processes. This settlement enables sustained investment in intelligence capability, broadens investigative reach, and reinforces efforts to recover criminal assets, including crypto assets, wherever they are found across jurisdictions, said Nick Ephgrave, the SFO’s director. The agency added that the cash has revived firm plans to relocate to new accommodation, probably in Canary Wharf, within around 18 months’ time. In February 2025, the SFO said budget pressures had forced it to...

The last time the government took the country's financial regulators off the beat When the government last eased pressure on the watchdogs, the Financial Services Authority ultimately paid the price, later conceding its weak supervision had worsened the 2008 crash. Today its successor, the Financial Conduct Authority, and other regulators are inching along a tightrope, apparently pulled between the government’s growth drive and their core duty to safeguard consumers and uphold orderly markets. Appearing before Parliament’s Treasury Committee on 10 June 2025, FCA chief executive Nikhil Rathi highlighted that the UK government’s stance on crypto-assets remains unclear, urging Parliament to define the national risk appetite—high, medium or low—to provide direction. He added that assessing how much risk or harm can be tolerated is “hard to measure” when trying to strike the right balance with growth. After years of pushing decisions out to...

Crypto wallets are digital instruments for holding and deploying digital assets. UK law enforcement have received enhanced, targeted powers to seize and access such wallets under the Economic Crime and Corporate Transparency Act 2023 ( ECCTA 2023). Authorities may freeze, manage, and ultimately forfeit cryptoassets in seized wallets where the funds represent the proceeds of unlawful conduct. Entry to a crypto wallet can be achieved in two principal ways—by possessing the private key that unlocks the wallet (non-custodial wallets), or through a centralised crypto exchange or other third-party hosting service providers (custodial wallets). In this piece, we set out how UK agencies can identify and take control of wallets for investigation and later forfeiture, and explore the limits of compulsory powers, particularly where the cryptoassets sit in non-custodial wallets. Custodial and non-custodial crypto wallets Grasping the distinction between these two wallet types will...

In this issue: Investigating criminal conduct Cross border criminal investigations Criminal procedure and evidence Bribery, corruption, sanctions and export controls Cybercrime and data protection offences Environmental offences Financial services and pensions offences Health and safety and corporate manslaughter offences Insolvency offences and Companies Act offences Money Laundering International Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Investigating criminal conduct Home Office introduces fresh Investigatory Powers Act codes of practice, with new Regulations now in effect The Home Office has brought three new codes of practice into effect under the Investigatory Powers Act. These address third-party bulk personal datasets, bulk personal datasets with low privacy expectations, and the notices regime. In addition, all existing codes of practice have been updated following their...

The Bill is a concise measure, aimed at addressing a handful of distinct issues within the Criminal Justice System, which are outlined as follows: the failure of an offender to appear for their sentencing hearing (clauses 1–2) the parental rights of convicted sexual offenders (clauses 3–4) the widening of victim’s rights for specified offences (clause 5) the enhancement of the powers and remit of the Victims’ Commissioner (clauses 6–8) changes to eligibility for appointment as a Crown Prosecutor within the Crown Prosecution Service ( CPS) (clause 9) revisions to the costs provisions for private prosecutions under section 17 of the Prosecution of Offences Act 1985 (clause 10) an alteration to the time limits for the Attorney General to refer an unduly lenient sentence (clause 11) amendments to six criminal offences concerning the range of...

Memo from US Deputy Attorney General Todd Blanche A formal memorandum issued by US Deputy Attorney General Todd Blanche makes clear that prosecutors will immediately prioritise FCPA probes and enforcement actions on wrongdoing committed by specific individuals, rather than ascribing 'nonspecific malfeasance to corporate structures'. The guidance also urges careful consideration of collateral effects on legitimate businesses 'and the impact on a company's employees, throughout an investigation, not only at the resolution phase'. Blanche further told the DOJ’s Criminal Division to advance investigative inquiries as swiftly as possible. In February 2025, President Donald Trump signed an executive order halting FCPA enforcement, on the grounds that it purportedly makes American firms less competitive. He also instructed US Attorney General Pam Bondi to update guidance for the federal statute, which targets global public corruption by supervising how American companies conduct business abroad. The 10 June 2025 memo sets out a...

Dana Astra IOOO v Secretary of State for Foreign, Commonwealth and Development Affairs [2025] EWHC 289 ( Admin) What was the background? The Secretary of State for Foreign, Commonwealth and Development Affairs (the FCDO) designated Dana, a major real estate and construction company active in Belarus, as an 'involved person' under the 2019 Regulations, SI 2019/600, made pursuant to s 1 of SAMLA 2018. Importantly, Dana was not domiciled in the UK and had no property, assets, or commercial interests within the jurisdiction. The FCDO considered there were reasonable grounds to suspect that Dana was an involved person for the purposes of Regulation 6 of the 2019 Regulations, SI 2019/600, because it: had engaged in the repression of civil society or democratic opposition in Belarus, or in other conduct, policies, or activities that undermine democracy or the rule of law in that state, in...

Andrysiewicz ( Appellant) v Circuit Court in Lodz, Poland ( Respondent) [2025] UKSC 23 Background On 23 September 2020, the Circuit Court in Lodz issued a request for the extradition of Ewa Andrysiewicz to Poland so that she could serve a two-year custodial sentence arising from four linked fraud offences committed between 2007 and 2008. That sentence had initially been suspended for five years but was later activated in full after she failed to comply with the suspension conditions. Following her arrest in London on 21 January 2023, Andrysiewicz contested extradition, arguing that her removal would be a disproportionate interference with her right to respect for private and family life under Article 8 of the European Convention on Human Rights ( ECHR). To advance her Article 8 case, she relied on the prospect that, if an application under the Polish Penal Code...

John Bedford, a partner at Dechert LLP, observed that a number of companies have approached him to clarify whether they can trade in securities that have remained frozen or otherwise blocked since Russia’s invasion of Ukraine more than three years ago. Others are exploring if they should start laying groundwork now to re-enter the Russian market after a prolonged hiatus, mindful of the lengthy lead time needed to re-establish and stabilise operations. Any prospective geopolitical reset becomes more complex if the UK and EU decline to follow America’s lead, leaving advisers to grapple with applying divergent, and potentially conflicting, regimes. For multinational businesses, obtaining permission in a single jurisdiction is far from straightforward, as they risk breaching, or being seen to breach, rules in other territories. Bedford warned that, even where firms consider themselves subject only to US sanctions or believe...

Across sectors where high‑value, cross‑border transactions are commonplace, exposure to financial crime is pronounced. Specific hazards include the possibility that assets traded are stolen or were acquired with the proceeds of crime; that either buyer or seller is implicated in terrorist activity; or that the asset functions simply as a vehicle for money laundering or terrorist financing. Although anti‑money laundering ( AML) controls—such as requirements to disclose suspicious activity—are now firmly embedded within many firms’ compliance procedures, the absence of parallel counter‑terrorist financing controls persists as a key weakness. There are important lessons to draw from Ojiri’s case. Art sales lead to hot water From October 2020 to December 2021, Ojiri is reported to have sold eight artworks, with a combined value of £140,000, to an individual alleged to be involved in terrorist financing. Although this individual was not personally designated under the UK...

Introducing a layered sanctions framework that permits adaptable reactions to varied hostile conduct is strongly urged in a paper from the Adam Smith Institute, the free-market think tank, and co-written by Robert Buckland KC. According to the report, such an approach would draw distinctions among modern forms of aggression, including cyber attacks, violations of human rights and economic subversion. The paper also lists environmental damage alongside political meddling as well. In addition, the institute argued that revising the legal meaning of ‘conflict’ would enable the UK to calibrate for differing degrees of risk and to take measured steps against state as well as non-state entities......

On 4 June 2025 at Southwark Crown Court, the Serious Fraud Office ( SFO) accused United Insurance Brokers Ltd of corporate misconduct, arising from its purported failure to prevent employees of a US-based intermediary from paying bribes to a state official in the South American country during the period October 2013 to March 2016......

The impact of cyberattacks The repercussions of hacking for organisations, across both public and private sectors, are wide-ranging and deep. Financially, the toll can be vast. IBM’s 2024 Cost of a Data Breach Report notes UK breaches now average nearly £3.6m; public sector incidents are a little lower on average, yet climbing quickly. Immediate spend covers incident response and the restoration of systems, while longer-term exposure includes potential regulatory fines, legal liabilities, and enduring reputational harm that can linger. For the LAA, reputational repercussions are already plain to see. The Law Society has openly criticised the Mo J’s handling of the breach, pressing government to ‘get a grip of the situation’ and to notify affected individuals directly. Trust—the bedrock of the legal system—has been unsettled. Legal aid applicants, many already in vulnerable positions, now carry the extra risk of identity theft, fraud, and...

What the review considered The review’s central aim was to place the prison population on a sustainable footing. It rested on three core principles: using custody to sanction the most dangerous, shaping sentences to reduce reoffending, and widening the role of community-based punishment. Meeting that challenge demanded a whole-system view of sentencing, recognising the links between prisons, probation, technology, and rehabilitation in the community. The proposed reforms The government has signalled it will, in principle, take forward most of the landmark proposals. These include: a presumption against prison terms under 12 months, favouring more robust community sentences earlier removal of foreign national offenders, with deportation after 30% of the custodial term has been served release timing placed more squarely on prisoner behaviour; those on standard determinate sentences will serve at least one-third, may spend longer inside for poor conduct, and there is no cap on how...

In this issue: Investigating criminal conduct Sentencing Bribery, corruption, sanctions and export controls Environmental offences Financial services and pensions offences Fraud, forgery, tax and theft offences Health and safety and corporate manslaughter offences Other corporate crime news Lex Talk®Corporate Crime: a Lexis®Nexis community Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Investigating criminal conduct Whistleblower rewards could soon take shape in the UK. The Serious Fraud Office ( SFO) will argue in favour of incentives for whistleblowers as part of a government-led fraud review. See News Analysis: Whistleblower rewards may soon materialise in UK. Sentencing Government to roll out far-reaching prison and sentencing reforms. England and Wales record the highest per capita prison population in Western Europe, with overcrowding worsening sharply in recent years....

What did the review look at and why? The review commenced in October 2024 to explore ways to bolster the UK's enforcement model. Overall oversight sat with the Foreign, Commonwealth and Development Office ( FCDO), and it incorporated input from HM Treasury, the Department of Business and Trade, the Department of Transport, HM Revenue and Customs, and the National Crime Agency. Furthermore, the process also drew on further meetings with various cross industry sanctions specialists, academics, and others, informing its conclusions......

The Water Services Regulation Authority ( Ofwat) hit Thames Water with a fine of £123m on 28 May 2025 for breaching rules governing its wastewater management and its unjustified payment of dividends. In imposing its biggest sanction to date, the regulator invoked 2023 powers—unused until now—that allow it to vary licences without firms’ agreement. Lawyers view the sanction as a clear warning that environmental, social and governance shortcomings rank among the foremost risks businesses face from Ofwat and other British enforcement bodies, describing the fine as a shot across the bows for companies across all sectors. Trevor Francis, a regulatory investigations partner at Blackfords LLP, said the case underscores the need for proactive legal and regulatory risk reviews across industries, particularly where environmental damage or customer detriment can be anticipated. The embattled utility has drawn fierce criticism from politicians and the public after...

Appeal by Dmitrii Ovsiannikov over UK Russia sanctions conviction Dmitrii Ovsiannikov, once a politician for Russia’s ruling party, has filed an appeal after his April conviction for breaching the UK’s Russia sanctions. He was found guilty of six counts of circumventing sanctions under the Russia ( Sanctions) ( EU Exit) Regulations 2019, SI 2019/855, alongside two counts of money laundering. At Southwark Crown Court, a judge handed the former Russian trade minister and ex‑governor of Russian‑occupied Sevastopol a 40‑month prison term. Liam Lane of Peters & Peters, who acted for Ovsiannikov, confirmed an application had been submitted on his behalf. Ovsiannikov’s brother, Alexei Owsjanikow, received a 15‑month sentence, fully suspended, after he too was convicted of circumventing sanctions for paying the school fees of Ovsiannikov’s children. Owsjanikow’s lawyer did not immediately respond to a request for comment. These convictions and sentences were the first in the UK for...

As the SFO's drive for whistleblower incentives gathers momentum, corporations should consider the implications for managing misconduct risk On 22 April 2025, the Home Office unveiled the second part of Jonathan Fisher KC’s fraud offences review, the first independent examination of UK fraud law since 1986. Spanning six phases of the fraud lifecycle, the opening phase features an in-depth appraisal of rewards for criminal informants and whistleblowers. The Fisher review is anticipated to be pivotal to the Labour government’s fraud agenda, offering the SFO a key platform to advance incentives reform within government. Soon after the announcement, the SFO stated it would liaise with the Fisher Review team to set out its case for change. These moves followed HM Treasury’s March 2025 commitment to introduce a fresh informants’ scheme aimed at tackling serious tax non-compliance, with a focus on major...

In this issue: Decision to prosecute and alternatives to prosecution Sentencing 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 Local authority prosecutions International Daily and weekly news alerts New and updated content Dates for your diary Trackers New Q& As Useful information Decision to prosecute and alternatives to prosecution UK may play major role in corporate misconduct regulation On 24 April 2025, the UK Serious Fraud Office ( SFO) released guidance setting out the principal considerations for prosecutors when assessing corporate enforcement, including the choice between bringing criminal charges against businesses or pursuing deferred prosecution agreements ( DPAs). See News Analysis: UK may play major role in corporate misconduct...