European Union
Anti-Corruption Directive
The first harmonised criminal framework across all Member States. Criminalises private-sector bribery and trading in influence. National laws due by 1 June 2028.
Adopted 21 April 2026
Anti-bribery and corruption
The enforcement map was redrawn. Most programmes were not.
Washington narrowed its priorities. Brussels, London, Paris and Bern did the opposite. A compliance programme built for the FCPA alone now has structural gaps, not cosmetic ones. This is where those gaps get mapped.
The jurisdiction tracker
Updated September 2026
United Kingdom
Failure to prevent fraud
A documented fraud risk assessment in its own right. The Home Office's own estimate of the work: 100 to 130 hours.
SFO DPA with Ultra, May 2026
United States
FCPA, refocused
Enforcement resumed in June 2025 under narrowed priorities: cartel links, harm to US competitors, national security and serious misconduct.
Guidelines issued 9 June 2025
UK, France, Switzerland
The Taskforce
The SFO, the Parquet National Financier and the Swiss Attorney General, coordinating cross-border bribery investigations directly with one another.
Formed March 2025
The Brief
What changed, and what it costs you
EU Directive
Your FCPA programme will not satisfy Brussels
Four gaps that a US-built compliance programme does not close, and what closing them actually involves.
Third-party risk
The distributor is the exposure
Agents, distributors and customs brokers sit behind most bribery cases. Why, and the four controls that actually reduce the risk.
United Kingdom
100 to 130 hours, documented
What a failure-to-prevent-fraud risk assessment has to contain before it counts as reasonable procedures, and why your bribery assessment does not cover it.
Self-disclosure
A promised declination, and a narrower window
The DOJ now promises a declination to companies that come forward. The catch is timing, and the number of authorities who may hear first.
Find out where your programme actually stands
A scored self-assessment against the Directive, the UK regime and current DOJ priorities. Fifteen questions, about five minutes, and a result naming your three largest gaps. No email needed until the end.
Practice
What the work looks like
Seven engagements and one free tool. Each is scoped to a fixed deliverable, and each says up front which entity delivers it.
- Themis Advisory Group Anti-bribery risk assessment A scored risk register by country, channel and counterparty, with a board-ready summary of where the exposure actually sits.
- Themis Advisory Group EU Directive readiness review A gap analysis against the Directive and the transposition law of your principal Member State, with a remediation roadmap sequenced by exposure.
- Themis Advisory Group UK failure-to-prevent-fraud assessment The documented fraud risk assessment and reasonable-procedures file the UK offence now requires in its own right.
- Themis Advisory Group Third-party risk programme Tiered due diligence, questionnaires, contract clauses and a screening workflow for agents, distributors and intermediaries.
- Themis Advisory Group Fractional chief compliance officer A named officer who owns the programme, reports to the board each quarter and is the escalation line when something surfaces.
- Oben Legal PLLC Privileged gap analysis When a review is expected to surface real exposure, it is run through counsel so the findings have the best chance of staying privileged.
- Oben Legal PLLC Internal investigations and self-disclosure Fact-finding into conduct that has already happened, and a recommendation on whether, where and when to disclose it.
- Free Readiness diagnostic Fifteen questions and a scored result, free, before anyone speaks to anyone.
The archive
Everything written since 2022, refiled
Four years of writing stays online, reorganised around the work: enforcement, integrity programmes, governance, and the technology now sitting inside both.
Enforcement
Charges, settlements and the policy shifts behind them.
Integrity programmes
How controls, culture and speaking up actually hold together.
Governance
Boards, leadership and the decisions that set the tone.
Compliance and AI
The technology now sitting inside both the risk and the controls.
Who writes this
Terence A. Oben
Attorney at law, New York
Fifteen years of legal, compliance and enterprise risk work inside institutions that were themselves under scrutiny.
JPMorgan Chase. BNP Paribas. Deutsche Bank. Banco Santander. Ericsson. Building control environments, running investigations, and carrying the consequences of getting either wrong, in organisations where regulators were already in the building.
That is the standard the work here is held to. Mid-market companies now face the same multi-jurisdictional exposure those institutions did, with none of the infrastructure. Closing that distance is the practice.
Two ways to engage
Programme work is advisory and runs through Themis. Anything that looks backward at conduct already in the past runs through the firm, where privilege attaches.
Themis Advisory Group
Build the programme
Risk assessments, EU Directive and UK readiness reviews, third-party due diligence architecture, training, and fractional chief compliance officer coverage. Fixed fee, scoped up front.
Go to ThemisOben Legal PLLC
When privilege matters
Internal investigations, self-disclosure analysis and legal opinions. A gap analysis that surfaces real exposure can be discoverable when a consultancy performs it. Run through counsel, it can be protected.
Request a confidential conversation