This session examined recent geopolitical and regulatory developments in anti-bribery and corruption (ABC) enforcement across the US and UK.
In the US, we discussed the post-inauguration developments under President Trump. Specifically: a renewed focus on dismantling cartels and transnational crime, alongside the temporary suspension, and review of FCPA enforcement via executive order; and the DOJ’s revised white-collar enforcement plan – emphasising voluntary self-disclosure, and cooperation. It also highlights key enforcement areas which signals a clear move to prioritise, bringing cases predicated on threats to US national security and business interests globally. This has been followed since we spoke with FCPA specific enforcement guidance which follows similar themes, and we can expect to continue in future DOJ pronouncements on this topic. We also explored the possibility of increased enforcement of the False Claims Act and other US statutes, in parallel with FCPA enforcement to further the Administration’s agenda.
In the UK, we covered the Serious Fraud Office’s strategic priorities, the new UK-France-Switzerland ABC taskforce, the upcoming “failure to prevent fraud” offence (effective 1 September 2025) and the possibility of the introduction of whistleblower incentives. We also discussed the expansion of corporate liability under ECCTA 2023 to incorporate economic crimes committed by senior managers and the Crime and Policing Bill, which proposes the expansion of corporate liability for senior managers acts to include non-economic offences like data protection and computer misuse.
