2025: A Year of Change in Bribery and Corruption Enforcement

2025: The Year of Change

2025 marks a turning point as political change sown in 2024 elections will begin to shape anti-corruption enforcement priorities across the globe. The U.S., UK, and EU are among key jurisdictions introducing significant reforms and recalibration of  enforcement strategies.

“Political shifts could redefine the global enforcement landscape in ways we’ve not seen before,” said Liam Naidoo, Deputy Head of Investigations, White Collar and Fraud at Hogan Lovells. “In the UK, the new Failure to Prevent Fraud offence, coming into effect in September, creates new compliance challenges for large organizations along with the prospect of a more active enforcement environment. Globally, corporations must navigate increasing regulatory complexity and adapt compliance frameworks accordingly.”

The report underscores how corporate criminal enforcement can be deeply intertwined with political dynamics, particularly in jurisdictions like the U.S., where the practices and policies of the Department of Justice (DOJ) may be influenced by political change. The report provides corporations with actionable insights to navigate heightened risks and adapt compliance frameworks to meet the challenges of an uncertain enforcement landscape.

Will 2025 be The Year of the Whistleblower?

The report poses the question of whether this year will be the "Year of the Whistleblower," driven by changes in EU law, an increased U.S. focus on disclosures, and calls for whistleblowing reforms in the UK. Companies are under growing pressure to enhance internal reporting mechanisms to minimise the risk of external whistleblowing.

“Governments around the world are continuing to focus on anti-corruption regulation and enforcement, and we saw numerous legal developments across the United States, Europe, APAC and Latin America,” said Stephanie Yonekura, Head of Investigations, White Collar and Fraud. “ “It’s even more important today for companies to take a careful look at how their compliance programs align with the laws and regulations in every jurisdiction in which they operate.”

AI and Technological Advances in Compliance

The interplay between technology and enforcement is set to reshape compliance strategies. With updated DOJ guidance emphasizing AI’s role in compliance programs and enterprise-wide data access, companies will need to integrate technological advances to drive efficiency and reduce costs.

“The integration of AI in compliance processes offers a promising opportunity to streamline efforts and manage costs,” said Yonekura. “However, companies are expected to assess risks associated with AI deployment and adjust their compliance programs to meet that risk .”

Regional developments to watch out for in 2025

The report provides an in-depth look at regional developments shaping bribery and corruption enforcement, including:

• U.S.: The Foreign Extortion Prevention Act (FEPA) makes it a federal crime for foreign officials to solicit or receive bribes.
• UK: The Failure to Prevent Fraud offense, effective September 2025, introduces new compliance risks for large organizations.
• EU: Progress on a harmonized anti-corruption directive and ongoing challenges with whistleblower protections.
• APAC & LATAM: Continued anti-corruption initiatives in markets such as Mexico, Indonesia, Singapore, and Vietnam, driven by government reforms and international collaboration.

For more insights, access the full Bribery & Corruption Outlook 2025 here.