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

Government publishes report from Independent Review of Disclosure and Fraud Offences 

The government launched an independent review into disclosure and fraud in October 2023, with the aim of speeding up criminal investigations and increasing the number of prosecutions. 

The chair of the review, Jonathan Fisher KC, has now published the second report of the review, "Fraud in the Digital Age". The report underscores that AI has "ushered in a new era of fraud", with criminals using increasingly sophisticated tools and techniques, making prevention and disruption at least as important as post-incident enforcement. 

Some of the key recommendations made by Fisher KC include: 

• Recommendation 2: Introduction of a new corporate criminal offence for providers of regulated user-to-user services (as defined under the Online Safety Act 2023) who fail to prevent fraud on their platforms. This offence would closely mirror the recently introduced failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act 2023, which holds large organisations criminally liable if they fail to prevent fraud committed by associated persons for their benefit. 
• Recommendation 15: Making legislative provision for the Serious Fraud Office (SFO) to financially reward whistleblowers, with a government consultation to inform the design of a suitable scheme. 
• Recommendation 16: Creating a new criminal offence for individuals who knowingly make false reports to law enforcement agencies under a whistleblower incentivisation scheme. 
• Recommendation 17: Establishing a criminal offence for those who harass or intimidate whistleblowers. 
• Recommendation 18: Establishing an independent arbitration panel to review appeals or complaints made by whistleblowers. 
• Recommendation 21: Reviewing theextraterritorial ambit of section 2(3) of the Criminal Justice Act 1987, with a view, in particular, to expanding jurisdiction to enable the SFO to serve notices on UK directors overseas and foreign corporates with sufficient UK nexus. 
• Recommendation 35: Updating the sentencing framework for serious fraud offences and money laundering, including increasing the maximum custodial penalties to 20 years to reflect the gravity and impact of these crimes. 
• Recommendation 36: The government should review and reform the current early guilty plea framework for complex fraud and economic crime cases, including an increased sentence discount for very early pleas, reflecting the significant savings in time and cost for the justice system and the benefit to victims. 
• Recommendation 39: The government should consider creating a separate statutory, court-supervised deferred prosecution mechanism for directors, senior managers and, where justified, other employees materially implicated in serious corporate economic crime. Any such mechanism would operate alongside corporate liability and should be capable of incorporating appropriate preventative measures, including restrictions akin to serious crime prevention order measures, where proportionate. 

We will report on the government's response when it is published in due course. 

HM Treasury updates advisory notice on high-risk third countries 

HM Treasury has updated its Money Laundering Advisory Notice: High Risk Third Countries. This follows the publication by the Financial Action Task Force (FATF) of its latest lists of jurisdictions with strategic deficiencies in their anti-money laundering and counter-terrorist financing regimes. 

HM Treasury advises firms to treat the following jurisdictions as "high-risk third countries" for the purposes of regulation 33 of the Money Laundering Regulations 2017, requiring enhanced due diligence measures: Angola, Bolivia, Bosnia and Herzegovina, British Virgin Islands, Bulgaria, Cameroon, Côte d'Ivoire, Democratic Republic of the Congo, Haiti, Iraq, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam and Yemen. 

The following jurisdictions are also designated as high-risk and are subject to a FATF call for action: Democratic People's Republic of Korea, Iran and Myanmar. 

The following jurisdictions are also subject to UK financial sanctions, requiring firms to apply further restrictive measures: Democratic People's Republic of Korea, Democratic Republic of the Congo, Haiti, Iran, Myanmar, South Sudan, Syria, Venezuela and Yemen. 

See the FATF update for further details.