United Kingdom: Corporate Crime

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).

As internal investigations surge amid heightened regulatory enforcement and whistleblower complaints, organizations face mounting pressure to handle complex inquiries spanning financial misconduct, HR disputes, and cross-border compliance challenges.

The Crime and Policing Act 2026 (the “Act”) extends the application of senior manager attribution provisions from economic crimes to all criminal offences.

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.

There are constant changes throughout the world, such as crime rates, that all countries need to monitor to ensure that their criminal procedures and law addresses the issues.

The Crime and Policing Bill 2025 expands liability, raising fresh debates over fairness, corporate culture, and culpability.

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.

Liam Lane's article in LexisNexis Corporate Crime analysis discusses a significant case involving the National Crime Agency (NCA) and its implications for future enforcement of sanctions breaches. The case suggests a potential shift towards stronger and more decisive actions by law enforcement agencies in addressing sanctions violations, with broader implications for how such breaches are handled moving forward.

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) expands corporate criminal liability by broadening the identification doctrine to include "senior management" beyond company officers. This statutory test aims to ensure legislative certainty and deter senior management from committing economic crimes within their authority.