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Jurisdiction tracker, updated September 2026

Four regimes, moving in different directions

The standard your programme is measured against depends on where you operate. This page tracks the developments that change it, and says plainly what each one means in practice.

European Union

Adopted 21 April 2026

Anti-Corruption Directive

Directive (EU) 2026/1021 on combating corruption was given final approval by the Council on 21 April 2026 and entered into force on 31 May 2026. Every Member State except Denmark must write it into national law by 1 June 2028. It covers bribery in the public and private sectors, misappropriation, trading in influence, obstruction of justice, enrichment from corruption and concealment.

For corporate bribery and misappropriation, each Member State must allow a maximum fine of at least 5% of worldwide turnover or, if it chooses a fixed ceiling instead, at least €40 million. For trading in influence, obstruction and enrichment the floors are 3% or €24 million. Companies can be liable where an offence results from a lack of supervision or control, and effective compliance measures count in mitigation.

What to watch: the transposition law in each Member State where you operate. The Directive sets the floor; national law sets the actual obligations, the penalty basis and how far jurisdiction reaches abroad.

United Kingdom

SFO DPA with Ultra, May 2026

Failure to prevent fraud

The failure to prevent fraud offence under section 199 of the Economic Crime and Corporate Transparency Act 2023 has applied since 1 September 2025. A large organisation, meaning one meeting two of three tests (more than 250 employees, more than £36 million turnover, more than £18 million in assets, measured across the group), is liable where an associated person commits a specified fraud intending to benefit it or its clients. The only defence is reasonable fraud prevention procedures. Non-UK organisations are in scope where the fraud has a UK nexus.

Government guidance treats a risk assessment as the starting point of those procedures, and the Home Office's impact assessment estimated one at roughly 100 to 130 hours of work. An anti-bribery risk assessment does not satisfy it on its own.

What to watch: the Serious Fraud Office approved a deferred prosecution agreement with Ultra in May 2026, its first foreign bribery DPA in nearly five years.

United States

Guidelines issued 9 June 2025

FCPA, refocused

The Department of Justice paused new FCPA enforcement under a February 2025 executive order, then resumed it on 9 June 2025 with revised guidelines. Prosecutors now weigh four factors: links to cartels and transnational criminal organisations, harm to fair competition for US companies, US national security interests, and the seriousness of the misconduct. A large number of open investigations were closed without charges.

The Criminal Division's corporate enforcement policy, revised in May 2025, now promises a declination, rather than a presumption of one, to companies that voluntarily self-disclose, fully cooperate and remediate, absent aggravating circumstances.

What to watch: the statute of limitations. Conduct left alone by one administration can still be charged by the next, and foreign competitors who win business by bribery are now an explicit target.

UK, France, Switzerland

Formed March 2025

The Taskforce

The International Anti-Corruption Prosecutorial Taskforce brings together the UK Serious Fraud Office, France's Parquet National Financier and the Office of the Attorney General of Switzerland. It was announced in March 2025.

Its practical effect is that a matter surfacing in one of the three jurisdictions is more likely to reach the other two, and sooner. The self-disclosure calculation now has to account for all three at once.

What to watch: the first jointly coordinated resolution, and whether other European prosecutors join.

This tracker summarises public developments for general information. It is not legal advice, and it is not a substitute for advice on how any of this applies to your organisation.

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