United Kingdom: Corporate Crime

The Crime and Policing Act 2026 (CPA 2026), which received Royal Assent on 29 April 2026, will significantly extend corporate criminal liability from 29 June 2026...

The Crime and Policing Act 2026 introduces a sweeping expansion of corporate criminal liability in the UK, extending the reformed identification doctrine to all criminal offences beyond economic crime. This fundamental shift means organisations can now be held liable when senior managers commit any criminal offence within their authority, with no reasonable procedures defence available.

The Crime and Policing Act 2026, which received Royal Assent on 29 April 2026, extends the application of the reformed corporate identification doctrine to all criminal offences (rather than just economic crimes).

Companies' compliance programmes have taken on increasing significance over recent years, with the introduction of a range of "failure to prevent" offences that can be committed irrespective of the company's involvement in...

Niall Hearty of Rahman Ravelli considers the findings of a Financial Conduct Authority survey.

OFSI's Review describes its progress against three priorities: improving compliance through clear guidance; building capability to deliver its service and functions; and enforcing sanctions proportionately and robustly.

A recent UK judgment in R (World Uyghur Congress) v National Crime Agency broadens the definition of "criminal property," complicating compliance for businesses. It challenges the adequacy of existing AML measures, intensifying due diligence and reporting burdens.

The FCA fined Starling Bank nearly £29 million for failing to improve anti-money laundering protocols, making it the largest UK regulatory penalty this year, signaling strict enforcement on compliance failures.

The UK's 'failure to prevent' model in corporate liability, extended to bribery, tax evasion, and now fraud, mandates strict liability for commercial entities unless they prove "reasonable procedures." However, ensuring foolproof internal controls to prevent misconduct remains challenging.