The Top 10 Headlines of 2025 – Investigations, White Collar and Investigations

Briefing

19 December 2025

11 MIN READ

3 AUTHORS

As the year draws to a close, we set out below a round-up of our 2025 Top 10 developments in the investigations, white collar and sanctions space.

1. Failure to prevent fraud offence in force/Directors Must Register KYC details at Companies House

The long-awaited coming into force of the corporate offence of failure to prevent fraud finally happened on 1 September 2025. As a reminder the offence was introduced in the Economic Crime and Corporate Transparency Act 2023 and applies to large organisations with a UK nexus. Enforcement Agencies have signalled their focus on using this new law. Have you checked your anti fraud procedures to make sure your business risk of prosecution for someone else’s failure is minimised? Details of what the Enforcement Agencies expect was published this year too. See 2. below.

Read more about the new offence here: https://www.hfw.com/insights/failure-to-prevent-fraud-in-commodities-the-deadline-looms/

In a move to reduce fraud involving UK Companies House UK Directors are reminded they must register their identity by November 2026 to avoid penalties.

2. SFO’s refreshed guidance on corporate compliance programmes

We have seen a strong push this year by the Serious Fraud Office (SFO) in respect of their approach to tackling corporate offending. This continued in November when the SFO published their refreshed guidance¹ on how it evaluates a company’s corporate compliance programme, updating the guidance previously published in January 2020, to cover the new ‘failure to prevent fraud’ offence. The new guidance distinguishes what constitutes ‘adequate’ procedures (defence to the failure to prevent bribery offence) and ‘reasonable’ procedures (defence to the failure to prevent fraud offence).

We recently published an article where we discuss the SFO’s refreshed guidance which can be found here: SFO Launches Refreshed Corporate Guidance on Self-Reporting and Co-Operation | HFW

3. HMRC Guidance on trade-based money laundering

Trade based money laundering (TBML) has been getting more attention from regulators and law enforcement authorities this year, with the current president of the Financial Action Taskforce (FATF) noting, at a joint experts meeting on 7 November 2025, that “… Trade-based financial crimes and fraud erode trust in financial systems and divert resources away from communities in need. These challenges are global, and they demand a united, strategic, and operational response”. This followed the publication by the UK’s HMRC of a TBML handbook², which details common TBML techniques, the legal framework and evidence-based case studies. One case study, ‘Operation A’, was an investigation by HMRC into a significant organised crime group which had used customs data to help identify the TBML activity. Have you read it? If not, you should.

Businesses, and particularly those in the regulated sector for anti-money laundering purposes, should review their AML policies, guidance and internal controls in light of this new guidance and update as necessary.

4. Regulators play catch up: FCA’s approach to crypto markets

The Financial Conduct Authority (FCA) continues its efforts to improve transparency and regulation of the UK’s crypto-assets market. Announcing in November that it had adopted the RegTech platform, ‘Eunice’ to develop standardised industry-led crypto disclosure templates which are designed to make it easier for firms to comply with document requirements, as well as ensure that potential investors are properly informed of the risks before making crypto investments³. Crypto is here already and regulators are playing catch up. We are seeing crypto feature increasingly in our cases. If you would like to understand more about it please reach out.

5. The US Foreign Corrupt Practices Act (FCPA) is dead. Long live the FCPA

Over in the US, November also saw the Department of Justice (DOJ) enter into the first Deferred Prosecution Agreement (DPA) of 2025⁴ against a corporate for violations of the Foreign Corrupt Practices Act (FCPA) and issue a fine of US$118.2m.

The DPA was entered into by Communiciones Celulares S.A. (doing business as TIGO Guatemala), a Guatemala-based telecommunications provider.

With the new “America First” policy of this US administration non US companies must remain vigilant. The FCPA should remain on your risk register. Antibribery enforcement in non-US jurisdictions remains a priority; for example see 6. below.

6. The International Anti-Corruption Prosecutorial Taskforce and the Launch of new UK’s new anti-corruption strategy

Demonstrating a continuing commitment to tackle bribery and corruption prosecutors in the UK, France and Switzerland announced in March an International Anti-Corruption Prosecutorial Taskforce. More recently, and just in time for International Anti-Corruption Day on 9 December, the UK government launched its new strategy to tackle bribery and corruption⁵ on 8 December. Just to underscore the importance given by the UK government of its anti corruption initiatives City of London Police has been given £15 million to police its remit of domestic corruption. Bribers beware.

7. Unexplained Wealth Orders

Unexplained wealth orders are used to force recipients to explain where they got their wealth from. If they are unable to provide an explanation demonstrating a legitimate source of wealth their assets can be taken from them. In January 2025, the SFO secured its first Unexplained Wealth Order⁶ (UWO) over a property in the Lake District in connection with the 2022 conviction of solicitor Timothy Schools over a fraudulent investment scheme. In September, the SFO finally managed to recover 1.1 million from the proceeds of sale of the property.

8. Competition law

The UK Competition & Markets Authority (CMA) has introduced a ‘4Ps’ framework designed to support the UK Government’s growth agenda and increase business confidence in the CMA’s regimes. The 4Ps are pace, predictability, proportionality, and process. These principles are being embedded in all areas of the CMA. In May 2025, Juliette Enser, Executive Director for Competition Enforcement at CMA, delivered a speech⁷ at CompLaw: Advanced EU, London, to explain how these principles will be introduced into the CMA’s competition enforcement work. Whilst the CMAs framework continues to be implemented, it represents a clear shift in the CMA’s approach, and one which hopefully will improve efficiency and effectiveness at the CMA and reduce uncertainty for businesses.

9. Sanctions

The sanctions landscape in 2025 continued to evolve at pace. The EU’s 19th package, adopted in late October, marked a significant tightening of restrictions on Russia’s energy sector and included a ban on short-term LNG contract imports within six months and long-term contracts from January 2027, and sanctions on over 115 vessels linked to the shadow fleet subject to port access bans. The EU also imposed full transaction bans on Russian oil majors, PJSC Rosneft Oil Company (Rosneft) and Gazprom Neft. Meanwhile the UK and US imposed full asset freeze and blocking measures respectively on Rosneft and PJSC Oil Company Lukoil (Lukoil).

In the US, enforcement also remained high on the agenda with OFAC imposing a $215 million penalty on a venture capital firm for managing assets of a designated oligarch. Concurrently, coordinated actions targeted Russian cybercrime infrastructure and signalled growing secondary sanctions risk for non-US entities facilitating sanctions evasion.

This year also saw the reduction of the Russian oil price caps (by the EU and UK). The UK also mirrored the EU by imposing shadow fleet designations while advancing domestic reforms to streamline its sanctions list and accelerate enforcement through a consultation on OFSI’s enforcement processes.

Additionally, the E3 (UK, France, Germany) triggered the UN ‘snapback’ mechanism in August, reinstating all prior multilateral sanctions on Iran, including arms and missile restrictions. This reversion to pre-2015 measures, coupled with renewed EU and UK autonomous sanctions, has reintroduced significant compliance risk across energy, banking, and transport sectors.

With nearly 80,000 sanctioned persons worldwide and mounting pressure on sectors, including maritime trade, 2026 is set to bring sharper focus on compliance, enforcement, secondary sanctions, and resilience against countermeasures. For businesses, the imperative remains clear: proactive risk assessment, robust due diligence, and agile compliance frameworks are no longer optional – they are effectively mandatory.

David Savage and Richard Soyoye wrote a review of the UK Governments Sanction Review, which can be found here (The UK Government’s Sanctions Review – A Path to Better Sanctions Implementation and Enforcement? | HFW)

10. FCA confirms final guidance to tackle serious non-financial misconduct

Following the July 2025 consultation and introduction of new rules to bring bullying, harassment and violence within the scope of what constitutes serious non-financial misconduct (NFM), the FCA confirmed it’s new guidance on 12 December 2025. The guidance covers how firms can apply the rules on minimum standards to behaviour for employees, and the factors to take into account when assessing if someone is fit and proper for their role.⁸

The new rules come into force on 1 September 2026 and apply to all firms with Part 4A permission. These firms should ensure that they consider the new rules and guidance and ensure that their internal policies, processes, and procedures for dealing with allegations of NFM are aligned with these changes.

What should businesses be doing?

Regulators and law enforcement authorities have prepared the groundwork for an enforcement push. Businesses should satisfy themselves they have taken steps to minimise their risks in these areas.

Your HFW team would be pleased to speak to you if you’d like to talk about any of the areas covered in this bulletin.

Footnotes