McGuireWoods London partner Francesca Titus examined the U.K. government’s new anti-corruption strategy and its significant implications for businesses in a Feb. 25, 2026, article in The Times.
Titus explained that fraud enforcement in the U.K. has been largely dormant since the COVID-19 pandemic. The Serious Fraud Office has faced challenges with disclosure, resourcing and recruitment; HM Revenue and Customs (HMRC) has recouped only a fraction of COVID-related fraud; and the Financial Conduct Authority (FCA) has focused primarily on prosecuting unregulated individuals.
The government’s new strategy signals a dramatic shift, wrote Titus, a partner in the firm’s Government Investigations & White Collar Litigation Practice Group. Corporations are now increasingly expected to police not only their own staff but all those with whom they do business, she explained. Organizations face potential criminal liability under three separate “failure to prevent” offenses if they fail to prevent fraud, bribery or facilitation of tax evasion — with fines so substantial they could collapse a business.
“Businesses of all sizes must take action, but many are either out of practice or have never operated in an enforcement environment,” Titus wrote. “They are going to need to shape up.”
The article also highlights renewed investment in enforcement, including HMRC doubling the size of its tax evasion team, expanded use of AI across agencies, increased data sharing with the private sector and the FCA’s expanding remit to supervise professional enablers of money laundering such as accountants and lawyers. Financial incentives for whistleblowers, modeled on successful U.S. programs, are also anticipated, Titus noted.