As 2026 begins, the UK is sharpening its focus on bribery, fraud and anti-money laundering (AML). The Serious Fraud Office (SFO) has released new guidance for businesses on identifying foreign bribery indicators, along with updated guidance on corporate cooperation. In addition, the government has published its UK Anti-Corruption Strategy 2025, outlining its approach to tackling corruption both in the UK and overseas.
SFO publishes foreign bribery indicators
As part of the International Foreign Bribery Taskforce (IFBT), the SFO has released guidance aimed at helping businesses identify and address potential instances of foreign bribery. The IFBT, which includes agencies such as the SFO and National Crime Agency (NCA) in the UK, as well as law enforcement bodies across the Five Eyes nations, has developed a common framework that draws on its collective experience of dealing with foreign bribery cases.
The guidance identifies six key categories of bribery risk:
- Conduct – Use of third-party agents, consultants, and shell companies.
- Government affiliations – Involvement with foreign government contracts or the need for foreign government permits or approvals.
- Country links – Connections to countries with a low Corruption Perception Index or where the business has no real connection.
- Ownership – Property ownership via trusts or cryptocurrency.
- Registration information – Misleading business descriptions or charitable registration anomalies.
- Other associations – Links to politically exposed persons (PEPs) or individuals with wealth far exceeding their public service salary.
While these indicators are not necessarily indicative of criminal activity, the guidance encourages businesses to assess the risk profiles of individuals and companies in high-risk sectors, and to take action where necessary. Compliance professionals and businesses are encouraged to review their current programmes and enhance them where appropriate.
The shift towards early detection and prevention of economic crimes is becoming more prominent, with a greater focus on identifying red flags before issues escalate.
UK Anti-Corruption Strategy 2025
The UK government’s Anti-Corruption Strategy 2025 outlines its approach to tackling corruption domestically and globally. The strategy is built around three main pillars: combating corrupt actors, addressing UK vulnerabilities, and strengthening global resilience.
Key elements of the strategy include:
- Stronger enforcement – The UK government plans to ramp up enforcement action against corruption, including reforms to the AML/CTF supervisory system. Professional services supervision will be consolidated under the Financial Conduct Authority (FCA), a move that will create a more cohesive and effective framework for addressing corruption.
- Whistleblowing reforms – The government is exploring reforms to the whistleblowing framework, potentially including financial incentives to encourage reporting of corrupt practices.
- International cooperation – The strategy outlines the creation of a new SFO-led international anti-corruption prosecutorial taskforce, which will enhance cross-border cooperation in investigating corruption cases.
- Fraud and AML strategies – The government has committed to publishing new strategies focused on fraud prevention and asset recovery, as well as addressing emerging risks in the AML space.
While the strategy is not a complete overhaul of the UK’s anti-corruption framework, it attempts to pull together existing laws and initiatives into a single narrative, fill some obvious gaps, and signal political intent. The government’s message is clear: the path to improvement lies primarily in better enforcement, stronger supervision, and more coordinated oversight, rather than a wave of new legislative duties.
SFO publishes corporate cooperation guidance
In a separate move, the SFO has released an updated guidance document detailing how it will evaluate corporate compliance programmes. This is a crucial document for organisations looking to understand how their compliance measures will be assessed during investigations, prosecutions, and eligibility for deferred prosecution agreements (DPAs).
The updated guidance stresses that the SFO will place particular focus on the Failure to Prevent Fraud offence, which came into force in September 2025 under the Economic Crime and Corporate Transparency Act. This new offence makes businesses criminally liable if they fail to prevent fraud, and the SFO will be prioritising enforcement in this area.
The SFO’s updated guidance also highlights the increasing use of artificial intelligence (AI) and machine learning to speed up investigations and improve efficiency in the fight against economic crime.
What businesses should do now
Review and strengthen compliance programmes: While no new laws are being introduced, businesses should ensure their current anti-corruption policies align with the government’s focus on enforcement. Review your procedures for detecting and preventing bribery, fraud, and money laundering, ensuring they are robust and actively monitored.
Enhance internal controls and reporting systems: Strengthening internal reporting systems for whistleblowers is key, as the government may incentivise reporting through reforms. Ensure that your employees have clear, confidential channels for reporting concerns.
Refresh training and communications: Update anti-bribery, fraud and AML training so it reflects current enforcement expectations and real-world red flags, including third parties, high-risk jurisdictions, and reporting obligations. Reinforce this with regular manager briefings and targeted training for higher-risk teams (sales, procurement, finance, and international operations).
Stay updated on enforcement trends: With a renewed focus on enforcement, businesses should be aware of the increased scrutiny from agencies like the Serious Fraud Office (SFO) and National Crime Agency (NCA). Ensure your business is prepared for more rigorous investigations and that your records are ready for inspection.
Collaborate with regulatory bodies: The strategy emphasises stronger coordination between law enforcement and businesses. Proactively engage with regulators and compliance experts to stay informed on best practices and regulatory expectations.
Prepare for ongoing scrutiny: The strategy’s focus on enhanced supervision means businesses must be prepared for more frequent audits and assessments of their anti-corruption measures. Regularly audit your anti-corruption frameworks to ensure they meet evolving expectations.
