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Horizon Scanning: Investigations and Enforcement

October 03, 2025
Andrew Reeves David Harris Stuart Neely Neil O'May Katie Stephen Claudia Van Gruisen Emily Smith default-contact-photo Lise Smit Maddi Parker Lubna Fahoum Grace Littlewood Catherine Pluck Rebecca Dulieu Joe Smallshaw
Andrew Reeves David Harris Stuart Neely Neil O'May Katie Stephen Claudia Van Gruisen Emily Smith Matthew Worby Lise Smit Maddi Parker Lubna Fahoum Grace Littlewood Catherine Pluck Rebecca Dulieu Joe Smallshaw
Posted in Business and human rights Capital markets Environmental and social governance (ESG) Fraud Investigations White-collar crime

In the latest edition of this horizon scan, our regulation and investigations team reflect on the most significant changes affecting companies operating in the UK and globally. The article focuses on developments including the issue of new cooperation guidelines by the Serious Fraud Office (SFO) and the abandonment by the Financial Conduct Authority of its proposal to “name and shame” those it is investigating. In addition, it reports on the SFO’s first use of an Unexplained Wealth Order, the Home Office’s progress report on its Economic Crime Plan 2, developments from the Solicitors Regulation Authority and Law Society, and more.

The team also look ahead to what they expect to see in the coming months, including:

  • a continued emphasis on corporate cooperation in an investigations context;
  • enhanced scrutiny of the effectiveness of corporate compliance policies and the implementation of those policies (noting the new failure to prevent fraud offence which came into force on 1 September 2025 and the recent first prosecution for failure to prevent tax evasion);
  • a review of the UK government’s approach to Responsible Business Conduct, including in relation to human rights and forced labour in supply chains.

Read the full briefing here.