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

SFO and CPS publish joint corporate prosecution guidance  

The Serious Fraud Office (SFO) and Crown Prosecution Service (CPS) issued updated joint guidance on corporate prosecutions, ahead of the "failure to prevent fraud" offence, which came into force on 1 September 2025. 

The new corporate criminal offence, which was introduced under the Economic Crime and Corporate Transparency Act, makes large organisations criminally liable if they fail to prevent fraud committed by an employee or agent for the organisation's benefit. 

Among other things, the joint guidance covers general principles and definitions; evidential considerations and forms of liability; and additional public interest factors to be assessed in prosecuting corporate entities. Businesses should read the guidance in conjunction with the guidance on reasonable fraud prevention procedures, to ensure that the statutory defence can be established.

To find out more, sign up for our Eating Compliance for Breakfast webinar, where our regulatory experts will discuss practicalities of the compliance measures required, risk management and the long-term implications of the new offence for businesses. 

See the CPS press release and read more in our Insight.

First prosecution of the failure to prevent the facilitation of tax evasion offence 

HMRC has brought the first corporate prosecution under the Criminal Finances Act 2017 (CFA) for failure to prevent the facilitation of tax evasion. Under the CFA, businesses commit a criminal offence if they fail to prevent an associated person (an employee, agent or third party who is performing services for or on behalf of the business) from facilitating tax evasion by a third party. 

Full details of the case have yet to be published, but it is understood that a UK accountancy firm has become the first business charged under the CFA. Six individuals have also been charged with offences including cheating the public revenue and money laundering. The offences relate to an alleged tax fraud in connection with research and development (R&D) tax relief and Covid-19 "bounce back" loans. A full trial is expected in 2027.

Our experts discuss the steps businesses should take in light of this key development in our Insight.

National Risk Assessment 2025  

HM Treasury published the fourth National Risk Assessment of Money Laundering and Terrorist Financing 2025, a comprehensive evaluation of these risks in the UK.

The latest NRA, which sets out the progress made since the last national risk assessment in 2020, sets out the sectors that remain vulnerable to money laundering, as well as new techniques and trends identified as being used by criminals to raise illicit funds. 

For further information on specific risks identified for financial services and property sectors, see our Insight.

Proposed amendments to money laundering regulations 

As previously reported, in its response to the 2024 consultation on the Money Laundering Regulations (MLRs), HM Treasury stated that it intends to introduce amendments to improve the effectiveness of the regulations by statutory instrument. 

It has now published a draft of the statutory instrument, alongside a policy note, detailing each proposed amendment and its policy intent. Among other things, the draft statutory instrument:

• intends to make customer due diligence more proportionate and effective, including through aligning transaction-based customer due diligence requirements for letting agents and art market participants;
• strengthens system coordination, cooperation and information between anti-money laundering and counter-terrorist financing supervisors and other public bodies;
• provides clarity on scope and registration issues, including by converting all monetary thresholds for customer due diligence, reporting and transaction triggers from euros to sterling; and
• reforms registration requirements for the Trust Registration Service, by expanding the categories of trusts required to register on the service. 

HM Treasury has launched a technical consultation, inviting feedback on the effectiveness of the draft statutory instrument. The deadline for responses is 30 September 2025. Subject to feedback and Parliamentary time, the government expects the final instrument to be laid in early 2026 and to come into force 21 days later.

NCA and FCA publish priorities to combat economic crime  

The National Crime Agency (NCA) and the Financial Conduct Authority (FCA) have published nine system priorities to combat economic crime, in line with the UK's Economic Crime Plan 2. 

The priorities, which are endorsed by the Home Office and HM Treasury, align with both the National Risk Assessment and the NCA National Strategic Assessment and aim to support the public and private sectors in effectively allocating resources in areas where they are most needed.

The nine priorities, which are considered to be equal, are as follows: 

• economic crime and sanctions evasion facilitated by professional services;
• transaction flows and corporate structures exploited by overseas politically exposed persons;
• protecting the public by creating a resilient cryptoasset ecosystem;
• criminal cash consolidation, cross-border movement and deposit into the UK banking system;
• money laundering in the UK or through UK corporate structures on behalf of international organised criminal groups with links to priority jurisdictions;
• fraud committed by international offenders targeting UK victims, including international organised criminal groups with links to criminality in priority jurisdictions;
• the exploitation of money mules for fraud and other purposes including terrorist financing;
• tackling the significant proportion of fraud losses originating from telecommunications services and online platforms; and
• terrorist financing in the UK, or individuals or groups engaged in attack planning or disseminating terrorist ideology. 

A newly created System Prioritisation Governance Group will oversee the governance of these priorities. Further guidance is expected to be published in due course to support firms in interpreting these priorities alongside the recently published National Risk Assessment (see more above and in our dedicated Insight).