Jurisdiction(s):
United Kingdom

Global anti-corruption compliance in 2025: US DOJ shifts, SFO DPA incentives and growing co-operation demand rapid self-reporting, robust investigations and integrated, risk-based programmes

Published on: 07 August 2025

Published by a Law360 reporter

Legal News

Article summary

The US Department of Justice has signalled notable shifts in corporate enforcement priorities. A six‑month pause in Foreign Corrupt Practices Act activity culminated in fresh guidance for prosecutors, while updates to existing DOJ policies have expanded rewards for voluntary self-reporting and strengthened incentives for whistleblowers. In parallel, overseas enforcement is evolving: recent guidance and legislation encourage disclosure and afford defences where robust compliance programmes are in place. At the same time, certain foreign authorities continue to champion cross‑border co-operation, a longstanding hallmark of assertive enforcers in an anti‑corruption arena historically led by the United States. Collectively, these movements recalibrate risks and incentives for global compliance programmes. Those charged with oversight should embed resilient reporting and investigation capabilities across all jurisdictions, balancing the DOJ’s new priorities with the more traditional focuses of foreign authorities. Crucially, the shifting landscape also offers concrete advantages, delivering a clear return for companies that invest in their compliance programmes and processes.

The shifts to the US enforcement outlook

The new administration moved quickly to reshape DOJ policies and priorities; shortly after taking office, President Donald...

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