Bribery, fraud and anti-money laundering | UK Regulatory Outlook April 2025

SFO publishes guidance on corporate co-operation and enforcement  

The Serious Fraud Office (SFO) has published new guidance on corporate co-operation and enforcement regarding corporate criminal offending. The guidance outlines the SFO's key considerations under the public interest stage of the Full Code Test for Crown Prosecutors when determining whether or not to charge a corporate entity or invite it to deferred prosecution agreement (DPA) negotiations. 

Key takeaways include an emphasis on the importance of prompt self-reporting and full co-operation for DPA eligibility. The guidance outlines expectations for self-reporting, co-operative conduct and timelines for investigation and DPA negotiations. The SFO anticipates that it will only be in exceptional cases where prompt self-reporting and co-operation may still result in prosecution. 

See the government press release. 

Regulatory Initiatives Grid  

The Regulatory Initiatives Forum published the eighth edition of the Regulatory Initiatives Grid, setting out the planned regulatory initiatives for the next 24 months. Key developments of interest to regulated firms are: 

• Financial Conduct Authority (FCA) enforcement transparency proposals: the grid notes that the FCA confirmed it will take forward aspects of its transparency proposals where there was greater support (see more in our previous Regulatory Outlook). As such, a "key milestone" is planned for Q2 (by the end of June 2025).
• Consultation on the Money Laundering Regulations: the Treasury is exploring reforms to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, which will introduce requirements for businesses to identify and prevent money laundering and terrorist financing (read more in our previous issue). The grid indicates that the government will proceed with a package of changes to the regulations in Q4 2025 (between October and December 2025). 

FCA page on cash-based money laundering 

The FCA updated its webpage on cash-based money laundering and its expectations of firms' controls. The FCA emphasises that firms should keep the impact of cash deposit controls under ongoing review to ensure the correct balance between money laundering prevention and impact on legitimate customers. It expects firms to utilise data to continue to refine controls as required, as money laundering risks evolve. 

With regard to next steps, as part of the new FCA strategy for 2025 to 2030, reducing the money laundering risk from cash deposits, including those at the Post Office, will remain a priority. The FCA also plans to launch a proactive multi-firm review in the financial year 2025/26, to assess the risk posed by other routes through which cash can enter the financial system, and how these channels might be abused by criminals. 

Law Society advice for law firms and legal teams on failure to prevent fraud offence 

The Law Society published advice aimed at helping law firms and legal teams prepare for the "failure to prevent fraud" offence introduced by the Economic Crime and Corporate Transparency Act 2023. 

The guidance sets out a helpful summary of the failure to prevent fraud guidance, and the six principles that firms should consider when designing and implementing reasonable procedures.  

See our Insight on the steps organisations should take in advance of the offence coming into force on 1 September 2025.