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    Feb. 25, 2026

2026 U.K. Enforcement Outlook: A Whole-Government Strategy to Fight Corruption

In December 2025, the U.K. Home Office issued its UK Anti-Corruption Strategy 2025 (Strategy), emphasizing growth, security and democratic protection. However, the future of enforcement grew uncertain when Nick Ephgrave, head of the SFO, announced in January 2026 that he would leave his post halfway through his five-year term. This second article in a two-part series on the 2026 U.K. bribery enforcement outlook examines the Strategy and the staffing changes at the SFO. Part one took a deep dive into the Guidance on Evaluating a Corporate Compliance Programme issued by the SFO in November 2025. See “The SFO’s Five-Year Strategy: Rebooted, Recharged and Ready to Rumble?” (Jun. 5, 2024).

Making Sense of the Pause, Reset and Emergent Risk in FCPA Enforcement

FCPA enforcement after the guidance issued in June 2025 shows two parallel, but competing dynamics. On one track, the DOJ has curtailed enforcement, including early termination of DPAs, NPAs, monitorships and active investigations. On the other, it has pursued enforcement against individuals and a small number of companies where it can tie the conduct, however attenuated, to current policy priorities such as national security, cartels, critical infrastructure or major U.S. financial‑system touchpoints. The net result is an active but less predictable FCPA enforcement landscape in which the rationale for outcomes is not always immediately evident. In this guest article, A&O Shearman partner Paula Howell Anderson, with associates Justin Meshulam and Sanjna Ullal, analyze the most salient FCPA developments of 2025 and offer practical insights on identifying, assessing and mitigating emerging compliance risks. See this three-part series “2025 in Review”: White-Collar Enforcement the “Right Way” Remains a Priority (Dec. 17, 2025), DOJ Perspectives on How the Blanche Memo Restarted FCPA Enforcement (Jan. 14, 2026), and “Impact on In-House Teams and Their Defense Counsel” (Jan. 28, 2026).

What “Back to Basics” Under Chair Atkins Means for SEC’s Division of Enforcement

Although each new administration brings a degree of change, developments at the SEC have been swift and significant following the end of Chair Gary Gensler’s tenure. Chair Paul Atkins has indicated that he intends to move away from “ad hoc enforcement” and toward a steadier, more principles-based approach that focuses on the SEC’s core mission. A recent webinar explored how leadership changes and new policy directions are reshaping the efforts of the SEC’s Division of Enforcement, as well as the implications for those navigating the evolving regulatory environment. This article offers relevant takeaways from the webinar. See “Present and Former SEC Officials Discuss Strategy, Testimony, Proffers and Negotiations” (Mar. 12, 2025).

How 2025 Changes to U.S. and Chinese Export Controls and Data Laws Impact Companies

Compliance is an increasingly central theme for companies doing business in or with China as they navigate a growing number of both U.S. and Chinese regulations. Export controls and sanctions, which often include extremely technical and complicated rules with severe liability risks, including criminal prosecution, are particularly challenging, as are issues related to data sovereignty and privacy. A December 2025 PLI webinar provided updates on export controls and sanctions, privacy and data sovereignty, digital assets and M&A due diligence. This article summarizes the key takeaways from the program. See “China and India Pose Compliance Challenges With Legal Shifts” (Apr. 24, 2024).

Five Strategies for Navigating Cross-Border Investigations

An investigation in one jurisdiction is hard, but when multiple jurisdictions become involved, the complications increase exponentially. The number of stakeholders multiplies, laws in differing jurisdictions can conflict, and there can be significant spillover effects once regulators in other countries catch wind of an investigation. During a recent webinar, Gibson Dunn attorneys discussed the elements that can complicate cross-border investigations and suggested five strategies for managing them. This article distills their insights. See “How Internal Investigations Can Let the Compliance Team Shine” (Jan. 29, 2025).

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Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.