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

SFO secures £14.8 million from British defence supplier over failures to prevent bribery 

Ultra Electronics Holdings Ltd (UEH) has been ordered to pay a £10 million penalty and £4.8 million in SFO investigation costs within 30 days, following approval by Hillyard J of a deferred prosecution agreement (DPA) between the Serious Fraud Office (SFO) and UEH after it acknowledged accountability for failure to prevent bribery under section 7 of the Bribery Act 2010. 

The penalty was calculated by applying a 300% multiplier to the harm figures, with a 45% discount for admissions and co-operation, rather than the full 50% reduction available, reflecting UEH's late disclosure of its Oman misconduct in 2022, and a further 10% totality reduction. UEH are also required to provide yearly compliance reports for three years to the SFO to demonstrate the effectiveness of its anti-bribery and compliance programme. In sentencing, the judge emphasised and took into account that UEH, following its acquisition by funds managed by Advent International LP in August 2022, is effectively a different entity from the one that committed the offences. 

This is the SFO's first concluded corporate bribery DPA since its 2022 agreement with Glencore, reinforcing the SFO's ability to secure significant penalties against non-compliant entities. What is particularly notable is the benefit that new owners were able to derive from their own actions: cooperating with the SFO and implementing a compliance remediation programme after they purchased UEH. Behaviour post-acquisition was specifically called out in the DPA.  

EU anti-corruption directive published in the Official Journal 

Minimum rules on criminal offences and penalties for corruption have been introduced by Directive (EU) 2026/1021, which has now been published in the Official Journal. It will enter into force on 31 May 2026 and Member States must transpose it into national law by 1 June 2028. Preventative measures, including risk assessments and anti-corruption strategies, will be implemented at a national level by 1 June 2029.  

The directive covers bribery, misappropriation, obstruction of justice, trading in influence, illicit enrichment linked to corruption and private-sector corruption. It also harmonises penalties across Member States and reinforces co-operation between national authorities and EU bodies, including the European anti-fraud office (OLAF), the European Public Prosecutor's Office (EPPO), Europol and Eurojust. As a result, Member States must adopt and regularly update national anti-corruption strategies, conduct risk assessments and ensure robust systems on conflicts of interest and political financing transparency. 

These developments should help businesses with a multi-jurisdictional footprint to develop, adopt and oversee group-wide policies, systems and procedures to mitigate corruption and ensure compliance with applicable law.  

EU council adopts provisional agreement on EPPO and OLAF access to fight VAT fraud  

The Council of the European Union adopted a provisional agreement on a proposal for a Council Regulation amending Regulation (EU) 904/2010 on administrative co-operation and combating fraud in the field of VAT.  

The proposed regulation concerns access by EPPO and OLAF to key VAT data on cross-border business transactions, aiming to tackle intra-Community VAT fraud. In practice, the new framework will provide them with direct access to the information necessary to launch and support investigations under their respective competences. 

The European Parliament is expected to adopt its opinion on the file in July 2026, following which the Council will formally adopt the regulation.  

AMLA publishes reporting package to identify entities for direct supervision 

On 13 May 2026, the EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) published a reporting package to assist national competent authorities (NCAs) in identifying obliged entities that will come under AMLA's direct supervision from 2028. The package comprises a standardised reporting template and an interpretative note to ensure consistency across the eligibility assessment. Eligible obliged entities are credit institutions, financial institutions and groups of those entities operating in at least six Member States. 

NCAs will collect data by 15 August 2026, with AMLA expecting to finalise the provisional list of eligible entities by the end of September 2026. It plans to host a public webinar on 10 June 2026 to guide entities through the template. Financial institutions operating across six or more Member States should begin assessing whether they are likely to fall within scope and engage with NCAs once reporting obligations are confirmed. 

Crime and Policing Act 2026 receives Royal Assent 

The Crime and Policing Act 2026 received Royal Assent on 29 April 2026. It introduces significant changes to corporate criminal liability for fraud and bribery offences. The government has indicated an anticipated commencement date of 29 June 2026, though this has not been confirmed. 

Section 250 replaces the corporate criminal liability provisions in the Economic Crime and Corporate Transparency Act 2023 with a new and broader test: where a senior manager of a body corporate or partnership acts within the actual or apparent scope of their authority and commits a criminal offence under the law of England and Wales, Scotland or Northern Ireland, the organisation also commits that offence.  

Notably for fraud and bribery exposure, this test applies across all criminal offences rather than a specified list, meaning that organisations may now face direct criminal liability for fraud, bribery and related economic crime offences committed by their senior managers.  

A senior manager is defined as an individual who plays a significant role in making decisions about how the whole or a substantial part of the organisation's activities are to be managed or organised, or in actually managing or organising those activities.  

Organisations should review their anti-fraud and anti-bribery compliance frameworks to ensure adequate oversight of senior management decision-making in light of this expanded basis of liability.