1. Renewed regulatory and government focus — The United Kingdom’s Budget 2025 contained a number of measures aimed at strengthening its approach to economic crime. These included new whistleblower rewards in high-value tax fraud cases, a consultation on a proposal for a new criminal offence on tax evasion, and changes to economic crime levy bands. As part of His Majesty’s Revenue & Customs’ (HMRC) Strengthened Reward Scheme, individuals whose information leads to the collection of at least £1.5 million in unpaid tax may receive rewards of between 15% and 30% of the tax collected; however, the decision to make such payments remains at the total discretion of HMRC. As of 30 June 2025, HMRC had secured one — also the first-ever — charging decision for failing to prevent domestic tax evasion and separately had 11 live investigations into failure to prevent the facilitation of tax evasion offences, with a further 27 live opportunities for investigation under review. It remains unclear whether the Strengthened Reward Scheme will enhance the quality of information upon which HMRC will base its investigations, including investigations for the corporate failure to prevent the facilitation of tax evasion offences.
The UK subsequently published its Anti-Corruption Strategy at the end of 2025. The 100+ commitments in that strategy span several areas, and were designed to reduce the harm caused by corruption to the UK and UK interests overseas over the next five years. The strategy has three main pillars: (1) combatting corrupt actors and funds (such as strengthening enforcement by law enforcement agencies, increasing efforts to target so-called “professional enablers,” and the use of technology to speed up complex investigations); (2) tackling vulnerabilities to corruption in the UK (such as championing transparency in ownership structures, exploring whistleblower reforms, and simplifying and improving the supervision of anti-money laundering and counter-terrorist financing); and (3) building global resilience to corruption (such as hosting a Countering Illicit Finance Summit in 2026 and focusing on international partnerships and standards to combat corruption).
2026 may represent a year of significant change for the Serious Fraud Office (SFO). Barely two weeks into 2026, the Director of the SFO, Nick Ephgrave, announced that he will depart at the end of March, approximately halfway through his projected tenure. This announcement came alongside the news that the SFO’s Head of Bribery and Corruption, together with two senior lawyers, had decided to depart. The SFO’s five-year plan for 2024-2029 included among its key pillars the goals of increasing the pace of investigations and making bolder and more pragmatic decisions. Executing on these pillars at a time of change may prove challenging for the SFO. Still, with three trials in the diary for 2026 and the recent announcement of a new domestic bribery investigation, the SFO appears to have the appetite for the challenge. We may also see further international cooperation from the SFO in 2026, building on the anti-corruption taskforce it entered into with French and Swiss authorities. The Director of the SFO has historically indicated his preference for whistleblower rewards, citing the effectiveness of rewards in the United States; it remains to be seen whether the yet-to-be announced interim director or Ephgrave’s ultimate successor might consider this an area worth continuing to concentrate on. November 2025 also saw the SFO reaffirm the importance of effective financial compliance programmes. Going forward, the adequacy of compliance programmes may be central to decisions around prosecution and the negotiation and discharge of deferred prosecution agreements.
We may also see further enforcement actions by the Financial Conduct Authority (FCA) for financial crime failures, with recent enforcement outcomes against Nationwide Building Society and Starling Bank (both of which received multi-million-pound fines) serving as a reminder of the need to maintain effective financial crime controls. Going forward, the FCA has stated that it intends to deliver “impactful deterrence” through its enforcement actions.
2. Continuing economic crime reforms — 2026 will see the continued introduction of reforms under the Economic Crime and Corporate Transparency Act, which introduced important changes in the fight against financial crime. The government introduced the new failure to prevent fraud offence last year, and while the government gave companies a number of months to upgrade compliance frameworks in preparation, 2026 may see investigations being opened into this offence. The SFO has publicly stated its ambition to be the first to prosecute someone for this offence.
Further expansions to corporate criminal liability may be on the horizon through the Crime and Policing Bill, which is currently in the committee stage in the House of Lords. If passed, the bill would widen the scope of corporate criminal liability by allowing for all crimes committed by senior managers to be attributed to the corporate, rather than only specific economic crimes.
3. The rise of Companies House as a prosecutor — Companies House is an important player in the UK government’s armoury, as it combats and seeks to reduce the UK’s exposure to fraud. The introduction of updated enforcement guidance in late 2024 — alongside greater powers of investigation, enforcement, and the imposition of increased civil financial penalties — has established a renewed and engaged Companies House that is responsive to company obligations and failings. We have seen increasing and swift engagement with companies and their directors, with the Companies House issuing warning letters promptly, thereby establishing fixed time frames for compliance with Companies Act obligations. Companies House has more efficiently escalated matters charging decisions, putting more pressure on companies and their directors to comply with their duties. Companies and their directors may wish to enhance their internal procedures and processes, making them both effective and capable of compliance with the Companies Act obligations.
The Companies House’s decision to prosecute Sanjeev Gupta and his fellow directors for failing to file company accounts may be considered the most high-profile prosecution the authority has brought in years. Such a choice may indicate the authority’s endeavour and confidence. Originally set for July 2025, an application for judicial review in connection with restrictions imposed on arguments that can be run in Gupta’s defence has delayed the prosecution. No dates have been made public, but the outcome of this application and the prosecution itself may prove informative.
4. Turbulence and increased enforcement of UK sanctions and export controls – In 2025, the Office of Financial Sanctions Implementation (OFSI) issued six enforcement actions, the most in any year since its establishment, and published a number of targeted threat assessment reports, focused on the legal services sector, high-value goods and the art market, and crypto-asset and property dealers. Moreover, OFSI’s October 2025 annual review highlighted 240 active cases, of which more than half stem from its own investigation capabilities, rather than from self-reported sources.
We may receive the UK government’s response to its July consultation during the first quarter of 2026. Those results may include higher statutory maximum penalties (potentially increasing the cap to £2 million) and the introduction of settlement and early account schemes (allowing, where appropriate, those under investigation to provide a complete factual account to OFSI of the relevant matters), which may facilitate percentage discounts to financial penalties.
Given the current geopolitical mood, the UK government may leverage sanctions, trade restrictions, and tariffs to influence and shape policy, which may impose increased risk on companies and their compliance procedures. Companies may wish to remain flexible and engaged to adapt to the changes, which may occur with little-to-no notice.
5. Potential move to judge-only trials – In 2024, the then Lord Chancellor (Shabana Mahmood) asked Sir Brian Leveson to conduct an independent review of the criminal courts, particularly in light of the backlog of cases. Part 1 of the Independent Review of the Criminal Courts report included recommendations to reduce the number of jury trials and recommended that serious, complex fraud cases be heard by a judge, not a jury. The Justice Secretary, who has also proposed judge-only trials in a wider variety of criminal cases, has adopted that recommendation. The proposals have, however, sparked concern about the effect on the administration of justice and the proposals for the removal of juries for most criminal trials do not include evidence of the purported cost reduction to the criminal justice system. As His Honour Judge Geoffrey Rivlin KC stated in his January 2026 submissions to the Justice Committee on this topic: “That an issue of jury reform should arise at all is to be regretted. This is being, albeit unconvincingly, advanced as a significant solution to the ‘crisis’ in the criminal justice system…but it has inevitably become a major distraction from the fundamental problem – namely, the grave and prolonged underfunding of the system over at least 20 years”.