Fallon Alexis of QEB Hollis Whiteman has co-authored a chapter with Alison Pople KC on the development of compliance enforcement in the United Kingdom within Global Investigation Review’s Guide to Compliance.
The chapter examines the evolution of corporate criminal liability and regulatory enforcement, from the constraints through to the reforms introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA). It considers the new corporate offence of failing to prevent fraud, changes to the identification doctrine, and their likely impact on the prosecution of economic crime.
Other key areas addressed include:
- The role of the Bribery Act 2010, particularly Section 7 “failure to prevent bribery” offences.
- The use of Deferred Prosecution Agreements (DPAs) and the significance of corporate compliance programmes.
- Enforcement trends in relation to money laundering, tax evasion, fraud and sanctions.
- The importance of corporate culture, governance, and practical compliance frameworks.
The chapter also identifies lessons for corporates, including the need for effective and well-implemented compliance procedures, the importance of senior management engagement, and the growing scope of regulatory enforcement.
The Chapter can be found here.
This article was first published on Global Investigations Review in September 2025; for further in-depth analysis, please visit the GIR Guide to Compliance.