Latest UK Investigations Update

As we near the end of H1 of 2025, we reflect on the latest investigations and white collar news, give our insight into the Government’s sanctions review and its impact on enforcement, and predict what the second half of the year will bring.

Bribery and corruption

March and April have seen a flurry of activity in the UK white collar crime space, including several new investigations, convictions and raids.

In March, the UK’s Serious Fraud Office (SFO), France’s Parquet National Financier (PNF) and Switzerland’s Office of the Attorney General of Switzerland (OAG) joined forces and announced the launch of the new International Anti-Corruption Prosecutorial Taskforce in London, which promises sharing of knowledge and expertise and strengthens the existing ties between these three agencies.

This renewed effort to prosecute international bribery and corruption is notable, in circumstances where an Executive Order was signed a month earlier in the US which pledged to pause the enforcement of the FCPA to prioritise the competitiveness of US companies abroad. Although, we note that in May, the Criminal Division of the DOJ in the US issued new guidance on its white-collar enforcement priorities, reiterating that they are focusing on fraud that specifically implicates US national interests, undermines US national security, harms the competitiveness of US businesses and/ or enriches foreign corrupt officials.

We also previously wrote about the SFO’s new guidance on corporate self-reporting and co-operation released in late April, here.

In April, the SFO charged United Insurance Brokers Limited (UIBL) with the corporate offence of failing to prevent bribery, in relation to its allegations of bribery of state officials in Ecuador between 2013 to 2016 in order to secure re-insurance contracts worth USD 38 million. UIBL appeared at the Magistrates Court in a hearing in early May, however the company’s plea decision has not been made public (presumably due to reporting restrictions). If the company decide to contest the charge however and it proceeds to trial, this will be the first time a failure to prevent offence under section 7 of the Bribery Act 2010 will be put to a jury trial and a jury will have to grapple with the issues of whether a company had in place ‘adequate procedures’.

In the same month, the SFO conducted dawn raids and launched an investigation into Blu-3 and Mace Group in relation to the allegations of bribes paid relating to the construction of a data centre in the Netherlands. The raids were highly publicised and conducted with assistance from Monaco authorities. If the heavy-handed nature of these arrests is anything to go by, it will not be a surprise to see increased enforcement in the second half of 2025 along a similar vein.

Also in the construction industry, May saw three individual convictions of former Keltbray managers for receiving bribes in relation to labour contracts worth £1 million between 2012 and 2018 following a trial at Southwark Crown Court. The boss of a demolition company was also convicted for paying the bribes. This case was brought by the Crown Prosecution Services (CPS) arising from a Home Office investigation into demolition labour contracts.

Finally, at the end of May, the SFO announced they were charging the company director of UK-based AOG Technics with fraudulent trading in relation issuing airline parts with fraudulent documentation as to its original, status or condition, resulting in worldwide grounding of planes in 2023. This led to the SFO opening a joint investigation with the Portuguese authorities resulting in several arrests and the charging decision less than two years after the incident.

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As we predicted in our last bulletin, the SFO have shown to take decisive action in the first half of 2025 in relation to their new cases, such as announcing their new investigations concurrently as making charging decisions (in the case of UIBL and AOG) or conducting dawn raids (in the case of Mace and Blu-3). Coupled with the SFO’s strategic partnership with other international prosecutorial agencies and guidance released in line with their Business Plan, we expect this upward trend of enforcement to continue to ramp up for the second half of the year, reflecting both the increased speed of investigations as well as number of charging decisions being made in respect of long-running, existing investigations.

Unexplained wealth orders

In January this year, the UK’s Serious Fraud Office (SFO) secured its first Unexplained Wealth Order (UWO) against the ex-wife of an individual convicted for fraud, since they were introduced by the government almost seven years prior in 2017, against a property in the Lake District valued at £1.5 million.

As UWOs are civil investigative tools granted by the High Court using civil standard (that is, on a ‘balance of probabilities’ rather than the criminal standard of ‘beyond reasonable doubt’), the only other agency which has applied for and been granted UWOs has been the National Crime Agency (NCA).

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This case is notable in that the SFO applied for a UWO following the individual’s criminal conviction, in circumstances where UWOs were thought to be a tool to be used as an alternative to a criminal conviction. This perhaps demonstrates the SFO’s determination to civilly recover funds which have been fraudulently obtained and shows that they are indeed willing to “explore new methods to recover funds for victims and the public purse” [emphasis added].¹

The Economic Crime and Corporate Transparency Act 2023 (ECCTA)

ECCTA has introduced significant changes to the UK legal framework in order to increase transparency and decrease economic crime.  A number of provisions are already in force, but a number are due to come into force over the next year or so. 

They include the Failure to Prevent Fraud offence which comes into force on 1 September 2025. Here large organisations can be held criminally liable for fraud committed by an “associated person” for the benefit of the organisation. Organisations need to have their policies and practices updated by the autumn date as the only defence is to demonstrate that it had reasonable fraud prevention procedures in place. We previously wrote about the new FTP offence in January, here.

In addition, in Autumn 2025, date as yet unknown, the identification verification regime is due to come into force whereby specific individual related to an organisation e.g. directors, partners, PSCs, will have to have their identity verified and their verification code filed at Companies House.  Similar provisions for anyone who files information at Companies House are due to come into force in 2026. Further information about the identification verification regime can be found here.

Of importance for many organisations, though due to a change in the Companies Act 2006 brought in by the Small Business Enterprise and Employment Act 2016 rather than ECCTA, it is anticipated that the abolition of corporate directors, with limited exceptions, will come into force in 2026.

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It is now more important than ever for corporates organisations to get their houses in order in preparation for the Autum 2025 when the latest ECCTA changes come into force. Coupled with the upward trend in enforcement actions taken by the SFO, it should be a key priority for companies to not only ensure that they have reasonable fraud prevention procedures in place, but also to ensure that they are properly implemented and effective.

Footnote

1. SFO secures first Unexplained Wealth Order in £100m fraud case – GOV.UK