Bribery, fraud and anti-money laundering | UK Regulatory Outlook January 2026

SFO publishes foreign bribery indicators

The Serious Fraud Office (SFO), as part of the International Foreign Bribery Taskforce (IFBT), has published new cross-jurisdictional guidance on identifying foreign bribery indicators to help businesses and professionals working in high-risk sectors to identify, prevent and address potential instances of foreign bribery.

The IFBT (comprising the SFO and National Crime Agency in the UK, as well as law enforcement agencies across the Five Eye Nations) created a common framework, drawing on the collective casework experience of the members, which can be used by businesses that operate internationally.

The guidance highlights indicators across six categories, which are of relevance to individuals and companies with elevated risk profiles for engagement in corrupt practices:

• conduct – such as the use of third party agents or consultants and shell companies;
• government affiliations – such as where business involves foreign government contracts or requires foreign government permits, approvals or licences to undertake or operate business;
• country links – including where the individual or company has links to a country with a Corruption perception index score of less than 40 or is incorporated in a county with no real connection to that country;
• ownership – such as owning property through a trust or cryptocurrency;
• registration information – including the existence of a charity registered with the same name as the company or the business description does not align with the officeholders' occupation; and
• other associations – including an individual who is a politically exposed person (PEP), or has links to a PEP, whose wealth greatly exceeds their public service salary.

The guidance stresses that these indicators are common to other financial crimes, such as money laundering, and do not automatically equate to criminal activity. Instead, they highlight factors, which, when considered in combination, raises the risk profile of the individual or company and suggests that further evaluation and assessment is necessary.

The IFBT encourages compliance professionals, businesses in high-risk sectors and advisers to review the list and strengthen their programmes where necessary. Individuals are also encouraged to report any activity indicative of foreign bribery to the appropriate authority in their jurisdiction. In the UK, reports can be made to the SFO or the National Crime Agency.

The guidance demonstrates a broader shift in economic crime enforcement strategy, placing greater emphasis on early detection and prevention.

See the SFO press release.

UK Anti-Corruption Strategy 2025

The government published the UK Anti-Corruption Strategy 2025. The multi-year strategy details its approach to tackling corruption in the UK and overseas. The paper sets out commitments to prioritise stronger enforcement action, industry support and whistleblowing reforms.

The strategy is built on three pillars: corrupt actors, tackling UK vulnerabilities and global resilience. To support industry in preventing and identifying corrupt activity, the country's anti-money laundering and counter-terrorist financing (AML/CTF) supervisory system will be reformed by consolidating supervision for professional services under the Financial Conduct Authority (as previously reported in this Regulatory Outlook).

The government will also consult on whether to amend the UK's AML regulations to respond to emerging risks, and explore opportunities to reform the existing whistleblowing framework, including through potential financial incentives.

The government has committed to publishing a new, expanded Fraud Strategy, and a new Anti-Money Laundering and Asset Recovery Strategy, following the conclusion of the Economic Crime Plan 2023-2026 (read more in this Insight).

To support law enforcement teams in investigating corruption cases, the strategy commits to delivering a new SFO-led international anti-corruption prosecutorial taskforce, and a more efficient investigative process in the SFO, including the use of artificial intelligence and machine learning to speed up investigations.

See the government press release.

SFO publishes corporate cooperation guidance

The SFO has published an updated Guidance on Corporate Cooperation and Enforcement on how it will evaluate corporate compliance programmes. It aims to help organisations understand how their compliance measures will be assessed in enforcement contexts, including prosecution decisions and eligibility for deferred prosecution agreements (DPAs).

The SFO is keen to make early use of the new the failure to prevent fraud offence, and we anticipate that will influence its focus and conduct of investigations and prosecutions in 2026. Businesses should also prepare for the amendments to the Money Laundering Regulations (as previously reported), which is expected to come into force in early 2026, as well as the upcoming Anti-Money Laundering and Asset Recovery Strategy.

For more information see our Insight and the SFO press release.