10 years of the UK Bribery Act: Compliance enough to define law’s success? - Alun Milford quoted in Compliance Week

Imagine you are woken up one day with a loud knock at the door.  It is the police who have a warrant for your arrest pursuant to an extradition request from a European country which you visited on holiday a few years earlier. 

The Fair Work Agency (FWA) was established under the Employment Rights Act 2025 (ERA 2025) on 7 April 2026 as an executive agency of the Department for Business and Trade, consolidating labour market enforcement functions previously carried out by other authorities.  

The King’s Speech on 13 May 2026 signalled a clear intention to reduce the regulatory burden of the Senior Managers & Certification Regime (“SMCR”) by around 50%. Whilst the specifics of this wait to be seen, the objective must be considered in the broader context of the FCA seeking to promote economic growth through more streamlined and proportionate regulation, central to which is a pre-existing two phased set of reforms to the SMCR.

INTERPOL’s recent Spotlight feature on Red Notices presents a confident account of the organisation’s role in facilitating international police cooperation and securing the arrest of fugitives across jurisdictions. The article also serves as a useful reminder of the very significant practical and legal consequences that Red Notices can have individuals who become subject to them.

On 29 April, the Crime and Policing Bill received Royal Assent, and the Crime and Policing Act 2026 is now on the statute books.* It introduces a further, transformative expansion of corporate criminal liability in the UK so that companies may be held criminally liable where a “senior manager” commits an offence while acting in their actual or apparent authority, for all crimes. This marks a fundamental departure from the current senior manager framework under the Economic Crime Corporate Transparency Act 2023 (ECCTA) where, currently, corporate liability is restricted to economic crimes.  

Throughout 2025, health and safety prosecutions have affected every major sector, with courts issuing substantial fines and, in some cases, custodial sentences for directors or individuals. These prosecutions highlight persistent failings in work-at-height controls, vehicle and machinery safety, risk assessment, maintenance and the protection of both workers and the public.

Private prosecutions can offer a more efficient and effective way of accessing justice for victims and deterring further criminality.

The FCA has recently released its newsletter ‘Enforcement Watch 1’ (‘EW1’) – a new online publication providing legal practitioners and others involved in the financial services industry an invaluable insight into the regulatory body’s enforcement priorities, aims and policies.

Kingsley Napley is pleased to announce that Jonathan Grimes will become Head of our top-ranked Criminal Litigation team with effect from 1 April 2026.

This online safety update provides a summary of the significant changes to Ofcom’s implementation of the Online Safety Act 2023 and the regulator’s enforcement strategy over the last year, and their potential impact on tech companies.

The CPS’s June 2025 guidance on the forum bar marks a decisive narrowing of the circumstances in which prosecutor’s belief statements may be issued. Such statements (by which a domestic prosecutor expresses the view that the UK is not the most appropriate jurisdiction for prosecution) have often featured in litigation under sections 19B and 83A of the Extradition Act 2003.

On 18 August 2025, the Serious Fraud Office (SFO) and Crown Prosecution Service (CPS) published their Joint SFO-CPS Corporate Prosecution Guidance, intended for prosecutors who will make decisions about whether or not to prosecute a corporation.

In June the Ministry of Justice announced new legislation under the Victims and Prisoners Act 2024 which affects NDAs and confidentiality clauses.* Related guidance, published at the beginning of June, sets out the impact of this legislation on the enforceability of such agreements.

The  Leveson review has been billed as a once-in-a-lifetime opportunity to reform the court system, with 45 recommendations being presented to Lord Chancellor Shabana Mahmood.

In July 2024 the Office for Students (OfS) published guidance on a new condition of registration dealing specifically with harassment and sexual misconduct. That condition, ‘E6’, comes into force on 1 August 2025. As such, universities and colleges have had a year to ensure they comply.

On 16 July 2025, the Insolvency Service released its new five-year strategy towards tackling economic crime facilitated by companies to be implemented between 2026-2031. Despite an enthusiastic introduction to its plans as ‘ambitious’ and ‘transformational’, the four strategic pillars laid out in the strategy brief – to target more cases involving corporate structures and serious criminality; exploit emerging technology; collaborate closely with public and private sector partners; and recruit, retain and invest in its workforce – echo the agency’s existing commitments, as well as the aims of recently released strategies by adjacent organisations like the FCA, NECC and CPS.

As of 25 July 2025, new child safety duties under the Online Safety Act have come into force, requiring online platforms to implement robust safety measures to prevent children from accessing illegal or harmful content. The consequences for non-compliance are significant, making it essential for online providers to understand their new obligations.

Congratulations to our Financial Crime & Investigations team, who have won the Team of the Year award at the Chambers High Net Worth (HNW) Awards 2025.

As global crime evolves and political landscapes shift, the UK’s legal frameworks for international cooperation and extradition are showing their age. In a new blog, Rebecca Niblock explores the  Criminal Law Reform Now Network (CLRNN) Scoping Review   (June 2025) which makes a compelling case: the time for reform is now.

On 29 April 2025, the UK’s Competition and Markets Authority (CMA) published a consultation on proposed revisions to its leniency guidance for cartel cases. The changes are intended to reflect legislative changes, align with current enforcement practices, and enhance the clarity, accessibility, and effectiveness of the CMA’s leniency regime.