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SFO Publishes New Guidance on Evaluating Corporate Compliance Programmes

On 26 November 2025, the Serious Fraud Office (SFO) published its Updated Guidance on how it would evaluate a company’s compliance programme (the Guidance) for the purposes of prosecutions, considering defences to the ‘failure to prevent offences’ and assessing factors relevant to sentencing, among others. The new Guidance sets out six scenarios where the SFO may assess a compliance programme. A key addition is where an organisation will have a defence of ‘reasonable procedures’ for the purposes of the failure to prevent fraud offence under s.199 of the Economic Crime and Corporate Transparency Act 2023 (ECCTA). A significant portion of the Guidance focuses on the ECCTA defence, which is discussed in detail below. 

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December 18, 2025

Top 10 International Anti-Corruption Developments for November 2025

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past month, with links to primary resources. This month we ask: How did a Foreign Corrupt Practices Act (FCPA) resolution involving an alleged Guatemalan bribery scheme reflect the new U.S. foreign bribery enforcement priorities? What updates did the United Kingdom (UK) Serious Fraud Office (SFO) make to its corporate compliance guidance? What steps did France, Kuwait, the United Arab Emirates (UAE), and Morocco take toward enhancing their anti‑corruption efforts? The answers to these questions and more are here in our November 2025 Top 10.

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December 16, 2025

FCPA Enforcement is Back: Is Your Compliance Program Ready?

The Department of Justice (DOJ) message at the recent American Conference Institute Foreign Corrupt Practices Act (FCPA) conference was clear: FCPA enforcement is alive and well.

Deputy Attorney General Todd Blanche, Acting Assistant Attorney General Matthew Galeotti, and FCPA Unit Chief David Fuhr confirmed that after the pause in early 2025, enforcement has returned to a “more traditional cadence.” Even more striking: the DOJ’s whistleblower program has received more than 1,100 submissions since launch, with over 50 percent referred to prosecutors for investigation.

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How Advanced Learning Systems Are Changing Corporate Training

In industries where mistakes can lead to serious consequences, training is not just a routine requirement—it is a responsibility. Organizations working in regulated environments must ensure that employees fully understand procedures, safety standards, and compliance rules. As these industries continue to evolve, many companies are rethinking how they approach corporate learning and development. For a long time, corporate training focused mainly on completion. Employees were expected to finish assigned courses, watch presentations, and pass basic assessments. While this approach satisfied formal requirements, it often failed to prepare workers for real-world challenges. As operations grow more complex, the gap between theoretical training and actual workplace demands has become increasingly clear.

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How to Build a Successful Anti-Corruption and Whistleblower Program

Over the past 40 years of trial and error, we now know precisely how to create a successful whistleblower and anti-corruption program.  We know the specific procedures that nation-states must employ if they truly want to prosecute crimes such as foreign bribery, money laundering, tax evasion, and similar frauds. We know the role that Non-Governmental Organizations (NGOs), journalists, and human rights defenders must play in this process.  Most significantly, we also know the incredibly impactful results of creating, implementing, and enforcing modernized whistleblower and anti-corruption laws. We know that whistleblowers can win and the corrupt officials can be sanctioned, fined, and jailed. Before we discuss the procedures needed to create a successful transnational anti-corruption program, it is important to look at the results obtained in the handful of existing programs that are the models for future legislation:

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Crypto fraudster sentenced for 'epic' $40bn stablecoin crash

11 December 2025

A former crypto entrepreneur who was behind two digital currencies that collapsed and lost an estimated $40bn (£29.9bn) has been sentenced by a New York judge to 15 years in prison for an "epic" fraud.

Do Kwon, a South Korean national, was co-founder of Singapore-based Terraform Labs, which developed the TerraUSD and Luna digital coins. Kwon had admitted misleading investors about TerraUSD, a so-called stablecoin that was supposed to maintain its value against the US dollar. He was one of a number of crypto bosses to face charges in the US after digital tokens slumped in 2022, triggering the failure of several companies.

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TIGO Guatemala Paid Over $118M To Resolve Foreign Bribery Investigation

December 12, 2025