United Perspective: Anti-Bribery and Corruption Regulations in the UK by 2025 (Lexology Panoramic)
The White & Case-authored chapter in the latest Lexology Panoramic: Anti-Bribery & Corruption UK 2025 publication offers a comprehensive view of the UK's anti-bribery and corruption landscape in 2025. This extensive guide, first published on Lexology Panoramic - Anti-Bribery & Corruption UK 2025, covers recent trends, landmark investigations, and decisions in the field.
The chapter, authored by partners Jonah Anderson, Anneka Randhawa, and associate Ed Pearson, delves into several key points regarding UK and international anti-bribery and corruption law, agencies, enforcement, sanctions, landmark investigations, decisions, and recent trends.
Relevant Domestic and International Law
The chapter emphasizes the UK's existing legal framework, including the Bribery Act, and discusses proposals for new corporate offences such as “Failure to Prevent Fraud” to enhance behavioural incentives and corporate culture reform. It highlights the need for integrated, comprehensive legislation to replace the current patchwork of laws, including reforms in professional supervision, director liability, and political integrity measures covering lobbying and funding.
Enforcement Agencies and Roles
Key UK enforcement bodies such as the Serious Fraud Office (SFO), National Crime Agency (NCA), and Crown Prosecution Service (CPS) are noted for their evolving roles. The NCA’s involvement in politically sensitive cases, like the alleged gem-mining license scandal in Madagascar, and the CPS’s use of Deferred Prosecution Agreements (e.g., Entain) and pursuit of individual prosecutions (e.g., NatWest case) illustrate a broader appetite within UK institutions for white-collar crime enforcement.
Enforcement and Sanctions Trends
Enforcement has been patchy, with the UK sometimes lagging behind international counterparts like the US, which has aggressively pursued financial institutions (such as the $2 billion fine in the Danske Bank case). The enforcement trend in the US under the Foreign Corrupt Practices Act (FCPA) is shifting toward prioritizing individual misconduct and voluntary disclosures over corporate prosecutions, with incentives for cooperation.
Landmark Investigations and Decisions
The chapter references landmark international leaks like the Panama and Paradise Papers, underscoring the challenges of revealing global corruption networks. Examples from major cases highlight UK enforcement challenges compared to more aggressive US actions. The first CPS Deferred Prosecution Agreement with Entain and continuing prosecutions such as the NatWest case mark important UK enforcement milestones.
Recent Trends and Challenges
Transparency and smart regulation remain central themes, including calls for public registers of beneficial ownership to prevent abuse of trust structures and secrecy. The chapter stresses the threat posed by illicit foreign influence on UK politics and property – notably from Russian and Central Asian wealth – impacting national security and democratic institutions. While recent progress in sanctions policy has been made, enforcement is under-resourced and insufficient.
Policy and Strategic Outlook
The discussion points to a need for reallocating fines to enhance investigative capacity and leveraging private sector expertise, alongside convincing policymakers that anti-corruption efforts support legitimate economic growth and global investment. Anti-corruption is framed as essential to maintaining the UK's integrity and attractiveness amid geopolitical risks and reputational scrutiny.
The publication is not intended to provide legal advice. It is protected by copyright, and the link to download the PDF of the Lexology Panoramic: Anti-Bribery & Corruption UK 2025 publication can be found at https://www.lexology.com/panoramic. The service areas covered by the authors include White Collar/Investigations, and they are based in Western Europe. The publication was reproduced with permission from Law Business Research Ltd. For further information, the publication can be downloaded as a PDF from the Lexology website.
[1] Source: Lexology Panoramic: Anti-Bribery & Corruption UK 2025 [2] Jonah Anderson specializes in White Collar/Investigations, Tax, Energy, Financial Institutions, Technology, and Life Sciences and Healthcare. [3] Anneka Randhawa specializes in White Collar/Investigations, Tax, Mining & Metals, Technology, and Consumer & Retail. [4] Ed Pearson specializes in White Collar/Investigations, Economic Sanctions & Export Controls, and Regulatory & Compliance. All authors are based in the United Kingdom.
- The chapter, authored by White & Case partners Jonah Anderson, Anneka Randhawa, and associate Ed Pearson, provides insights into the UK's anti-bribery and corruption landscape in 2025, offering a discussion on how the Bribery Act and proposed corporate offences like “Failure to Prevent Fraud” can impact the legal practice in this area.
- The comprehensive guide covers trends, landmark investigations, and decisions related to international laws such as the Foreign Corrupt Practices Act (FCPA) and enforcement in countries like the United States, where financial institutions like Danske Bank face substantial fines.
- The chapter underscores the evolving roles of UK enforcement bodies, like the Serious Fraud Office, National Crime Agency, and Crown Prosecution Service, which have shown a broader appetite for white-collar crime enforcement through the use of Deferred Prosecution Agreements and individual prosecutions.
- The publication highlights the need for integrated, comprehensive legislation to address the current patchwork of laws, including reforms in professional supervision, director liability, and political integrity measures covering lobbying and funding, to ensure effective regulatory compliance in businesses.
- The authors stress the importance of transparency and smart regulation, advocating for public registers of beneficial ownership and leveraging private sector expertise to bolster investigative capacity in the face of illicit foreign influence on UK politics and property.
- The authors emphasize that anti-corruption efforts are essential to maintaining the UK's integrity and maintaining its attractiveness to global investment in the face of geopolitical risks and reputational scrutiny. Their service areas include White Collar/Investigations, and they are based in Western Europe.
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