Robertson Pugh | Elizabeth Robertson and Paddy Ferguson
Year in review
The year 2025 was marked by significant developments in the UK bribery and corruption landscape, both in enforcement activity and legislative developments. Nevertheless, the future landscape is difficult to chart, with longstanding question marks about UK regulators’ ability to enforce the jurisdiction’s seemingly robust enforcement toolkit.
Historically, the US has been a major partner to the UK in the investigation and enforcement of suspected complex and international bribery and corruption offences. For instance, the UK collaborated with the US in relation in relation to several high-profile DPAs and related enforcement actions in circumstances in which the US Department of Justice and/or the US Securities and Exchange Commission were running parallel or coordinated actions. These include the DPAs reached with Airbus, Standard Bank and Rolls Royce. However, since President Donald Trump’s pause on enforcement of the US Foreign Corrupt Practices Act in February 2025,1 it is expected that the UK will have to become less reliant on trans-Atlantic corruption investigation collaboration, and attention has turned closer to home. While the UK has looked to improve enforcement collaboration with European nations (indeed, the SFO joined a new International Anti-Corruption Prosecutorial Taskforce with France and Switzerland in March 2025),2 its strategic recalibration will necessarily also involve greater introspection and a refocus on domestic enforcement.
The SFO has committed to delivering at least one successful outcome in over 80% of its cases (including at least one conviction or DPA) and securing, by jury or guilty plea, a 60% conviction rate of defendants, both corporate and individuals, in its “Strategic Plan for 2022-2025” paper published in April 2022.3 In its “SFO Strategy 2024-29” paper published in May 2024,4 the SFO admitted that “justice delayed is justice denied” and restated its ambition to build compelling cases in shorter timescales.
Nevertheless, the SFO has faltered in its prosecution of individuals. The SFO failed in its prosecution of individuals from Serco Geografix and G4S, notwithstanding the DPAs which it entered into with the corporates, while the convictions it secured against two former Unaoil executives and a former SBM Offshore executive were overturned by the Court of Appeal. The common theme across each of these cases was the SFO’s disclosure failings. In particular, an independent review into the SFO’s handling of the Unaoil case conducted by Sir David Calvert-Smith identified “a significant number of fundamental failures”, which had to be addressed if the SFO was to learn from the case.5
This has been a continuing theme. In a further blow to the agency, it was announced in February 2026 that the SFO was discontinuing its decade-long prosecution of three individuals connected with London Mining Plc allegedly involved in the bribery of public officials in Sierra Leone, on the basis that the case no longer met the threshold for criminal proceedings to proceed.6 The individuals were due to face trial in April 2026. In November 2025, the SFO was reported to have discovered over 500,000 documents, which it had collected but failed to review as part of its investigation due to an issue relating to its document review software. In parallel, the SFO announced a review of approximately 20 past cases in light of an identified issue with its legacy eDiscovery software.7
Nevertheless, both the SFO and the CPS have significant trials against individuals for bribery offences listed and will be looking to tilt the prosecutorial record in their favour. The SFO has charged six former Glencore employees with conspiracy to make corrupt payments in connection with the awarding of oil contracts in West Africa between 2007 and 2014.8 They have all entered “not guilty” pleas and the trial is listed to start on 4 October 2027. More proximate still, the trial of two former Petrofrac senior executives charged with bribery offences in relation to the award of infrastructure and design contracts for oil facilities is listed to start in October 2026.9
In parallel, the CPS is prosecuting 11 individuals employed by or connected to Entain, with investigatory support from HMRC. The charges include conspiracy to bribe in connection with the provision of gambling services in Turkey between 2011 and 2018.10 The trial is provisionally listed to start in 2028, although the defendants have not yet entered pleas.
While the SFO did not complete any trials against corporates for bribery or corruption offences in 2025, it did charge United Insurance Brokers Limited with the corporate offence of failing to prevent bribery under section 7 of the Bribery Act in April 2025.11 The charge relates to the alleged payment of bribes by company agents to Ecuadorian officials in connection with reinsurance contracts.
Neither the SFO nor the CPS has entered into a DPA since the CPS agreed terms with Entain in December 2023. However, the SFO has been engaged in a bid to enforce the DPA which it entered into with Güralp Systems Ltd (Güralp) on 22 October 2019. In June 2023 Guralp wrote to the SFO, stating that it might not be able to meet its financial obligations under the DPA and that a variation of the terms might be needed. The SFO proposed terms for a payment plan. No response was received by 22 October 2024, being the date on which the DPA’s effective period was due to end, at which point the SFO applied for a hearing to deal with the breach. On 21 November 2024, the SFO informed the court that it believed the terms of the DPA had been breached and requested a hearing at Southwark Crown Court to take the matter forward. On 31 January 2025, the High Court ruled that the SFO could apply to proceed with action against Güralp in respect of its breach of the DPA. This was the first time that the SFO had sought to take action against a company for breaching the terms of a DPA. In a judgment dated 13 January 2026, the High Court confirmed that the SFO can take enforcement action against Güralp.12
The SFO can now request that the court terminate the DPA and lift the suspension of the draft indictment, thereby reopening the prosecution.
The UK’s enforcement of bribery offences is pockmarked with prosecutorial failures. Nevertheless, a number of significant trials lie ahead, and both the government and its law enforcement agencies are taking legislative and practical steps to strengthen their enforcement arsenal.
This article first appeared on Lexology | Source
