Background and Conference Focus
The conference in London on July 9, 2025, featured a pivotal session titled “US and UK Enforcement in the Current Climate: Strategic Shifts and Global Implications.” Legal experts from both sides of the Atlantic explored how enforcement practices are evolving in major jurisdictions including the UK, US, and Latin America, and where companies need to focus in response.
UK Enforcement: The SFO’s New Playbook
The UK’s Serious Fraud Office (SFO) has refined its case selection process and increased interagency cooperation. With the Economic Crime and Corporate Transparency Act (ECCTA) coming into force in September 2025, corporate liability is expanding. Senior managers, not just board members, could now face criminal charges for failures including fraud and ESG-related misconduct such as greenwashing.
During the conference, SFO’s Case Controller David Knott and other speakers highlighted the agency’s new dawn raids and stronger whistleblower incentives. It is a clear signal of more aggressive enforcement on the horizon.
US Enforcement: A Strategic Recalibration
On February 10, 2025, an Executive Order paused new Foreign Corrupt Practices Act (FCPA) enforcement for 180 days and triggered DOJ policy reviews. But instead of stepping back, the DOJ issued new guidance shifting FCPA enforcement to focus on national security threats and unfair competitive practices by foreign entities.
Despite the federal pause, the SEC and state attorneys general continued enforcement. In states like California, prosecutors stepped in to fill the gap, and the SEC maintained civil actions under FCPA authorities.
Global and Regional Spillovers
Latin America is firmly in the spotlight. Countries like Brazil and Chile are introducing new liabilities for corporate misconduct. Meanwhile, varying rules on legal privilege and data protection across jurisdictions make cross-border investigations more complicated. Speakers stressed the importance of adapting compliance strategies to reflect local rules and risks.
At the same time, coordinated actions between UK, French, Swiss, and other authorities are bridging enforcement gaps and moving toward a more unified global compliance framework.
Why It Matters to Compliance Teams
The enforcement landscape is becoming more complex and demanding. In the UK, ECCTA is expanding liability beyond the traditional boardroom. In the US, changes in DOJ focus and growing state-level activity mean risk could come from unexpected places. Latin America is advancing fast, making strong internal controls a necessity.
Compliance teams need to stay alert and adaptable. That means updating internal policies to align with regional laws, keeping tabs on interagency moves, and preparing for faster, tougher investigations.
Practical Takeaways
- Expect stronger UK enforcement under ECCTA, with broader reach and lower thresholds for corporate liability.
- US enforcement has evolved, not disappeared. Targeted FCPA actions and state-level oversight are rising.
- Design compliance programs that can flex across jurisdictions and legal systems.
- Watch Latin American developments and tailor internal investigations to local privilege and data handling requirements.
Final Thoughts
This conference delivered a clear message: anti-corruption enforcement is entering a new chapter. The UK is expanding its legal reach and working more closely with global partners. The US is focusing on national and economic security. Latin America is becoming more assertive.
Compliance is no longer just about avoiding penalties. It is a strategic necessity. Companies that build a strong ethical culture, invest in global compliance systems, and prepare for legal complexity will not only manage risk—they will set the standard.
