UK and EU Enforcement Update and Practical Compliance Takeaways
עדכון אכיפה בבריטניה ובאיחוד האירופי ועקרונות מעשיים בנוגע לציות
Question: What are the recent enforcement actions across the UK and EU that highlight enforcement priorities and underline patterns of behavior that should be avoided?
Answer: Amid shifting global enforcement dynamics, UK and EU authorities have continued to pursue robust anti-corruption and sanctions enforcement. European regulators are increasingly advancing complex, cross-border cases, frequently targeting both corporations and individuals and relying on expansive corporate liability doctrines. The 2025 enforcement landscape reflects consistent themes: third-party risk, procurement corruption, executive accountability, whistleblower escalation failures, and the growing convergence of sanctions and anti-corruption exposure, as highlighted in the examples below:
UK: Failure toPrevent Bribery and Overseas Procurement Corruption
In April 2025, the UK Serious Fraud Office charged a UK insurance broker under the 'failure to prevent bribery' offense of the UK Bribery Act in connection with alleged corrupt payments routed through intermediaries to secure public-sector contracts in Ecuador.
Key issue: Third-partycommission payments without adequate controls remain a primary enforcementtrigger.
In May 2025, the Crown Prosecution Service charged a UK businessman in connection with alleged bribery of foreign public officials in Malawi tied to military procurement contracts.
Key issue: Public procurementin high-risk jurisdictions remains a core enforcement focus.
EU: Lobbying and Corruption
In April 2025, Belgian prosecutors charged multiple individuals in connection with alleged improper payments by Chinese telecommunications provider Huawei designed to secure legislative support from Members of the European Parliament. The charges included corruption, money laundering, and criminal organization participation.
Key issue: Lobbying and legislative engagement carry material corruption risk.
France: Tenders, Third-Party Bribery and Kickbacks
In February 2025, two French companies agreed to financial penalties to resolve allegations involving kickbacks, improper access to bidding information, and bribery of foreign public officials in Algeria.
Key issue: Tender manipulationand improper competitive intelligence remain recurring enforcement drivers.
In June 2025, a French cyber security company resolved allegations involving third-party bribery in India, Indonesia, Malaysia, Thailand, and Vietnam, including reported failures to act on internal compliance concerns.
Key issue: Unsupervised use of third parties in high-risk jurisdictions and failure to respond to internal compliance reports increases enforcement risk.
In September 2025, a French security technology company resolved allegations involving overcharging and kickback arrangements with a Ukrainian state-owned entity.
Key issue: Overcharge-and-kickback structures in public contracting remain actively prosecuted.
Netherlands
In April 2025, the Dutch Public Prosecution Service brought bribery and sanctions charges against a ship building company relating to inflated commissions, falsified documentation, and alleged violations of Russian sanctions.
Key issue: Anti-corruption and sanctions enforcement are increasingly converging.
The cross-Jurisdictional enforcement patterns outlined above highlight the following areas of focus for any compliance or legal professional or Board member of an Israeli company:
• Third-party intermediaries remain the dominant risk vector.
• Public procurement and state-owned entities are high-risk areas.
• Individual liability is expanding.
• Ignored red flags and compliance failures are aggravatingfactors.
• Sanctions and corruption exposure are increasinglyinterlinked.
To address the above and prevent any compliance failures werecommend to:
• Reassess third-party due diligence and commission structures.
• Integrate sanctions and anti-corruption controls into aunified framework.
• Strengthen procurement-focused compliance reviews.
• Ensure documented escalation of compliance concerns.
• Provide board-level visibility into high-risk engagements.
*The contents of this message, current at the date of publication, are for reference and general informational purposes only and do not constitute legal advice. You should contact your attorney to obtain advice with respect to any particular legal matter. You should not act or refrain from acting on the basis of information in this publication without first seeking legal advice from counsel in the relevant jurisdiction. Only your individual attorney can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation.
עדכון אכיפה בבריטניה ובאיחוד האירופי ועקרונות מעשיים בנוגע לציות
Question: What are the recent enforcement actions across the UK and EU that highlight enforcement priorities and underline patterns of behavior that should be avoided?
Answer: Amid shifting global enforcement dynamics, UK and EU authorities have continued to pursue robust anti-corruption and sanctions enforcement. European regulators are increasingly advancing complex, cross-border cases, frequently targeting both corporations and individuals and relying on expansive corporate liability doctrines. The 2025 enforcement landscape reflects consistent themes: third-party risk, procurement corruption, executive accountability, whistleblower escalation failures, and the growing convergence of sanctions and anti-corruption exposure, as highlighted in the examples below:
UK: Failure toPrevent Bribery and Overseas Procurement Corruption
In April 2025, the UK Serious Fraud Office charged a UK insurance broker under the 'failure to prevent bribery' offense of the UK Bribery Act in connection with alleged corrupt payments routed through intermediaries to secure public-sector contracts in Ecuador.
Key issue: Third-partycommission payments without adequate controls remain a primary enforcementtrigger.
In May 2025, the Crown Prosecution Service charged a UK businessman in connection with alleged bribery of foreign public officials in Malawi tied to military procurement contracts.
Key issue: Public procurementin high-risk jurisdictions remains a core enforcement focus.
EU: Lobbying and Corruption
In April 2025, Belgian prosecutors charged multiple individuals in connection with alleged improper payments by Chinese telecommunications provider Huawei designed to secure legislative support from Members of the European Parliament. The charges included corruption, money laundering, and criminal organization participation.
Key issue: Lobbying and legislative engagement carry material corruption risk.
France: Tenders, Third-Party Bribery and Kickbacks
In February 2025, two French companies agreed to financial penalties to resolve allegations involving kickbacks, improper access to bidding information, and bribery of foreign public officials in Algeria.
Key issue: Tender manipulationand improper competitive intelligence remain recurring enforcement drivers.
In June 2025, a French cyber security company resolved allegations involving third-party bribery in India, Indonesia, Malaysia, Thailand, and Vietnam, including reported failures to act on internal compliance concerns.
Key issue: Unsupervised use of third parties in high-risk jurisdictions and failure to respond to internal compliance reports increases enforcement risk.
In September 2025, a French security technology company resolved allegations involving overcharging and kickback arrangements with a Ukrainian state-owned entity.
Key issue: Overcharge-and-kickback structures in public contracting remain actively prosecuted.
Netherlands
In April 2025, the Dutch Public Prosecution Service brought bribery and sanctions charges against a ship building company relating to inflated commissions, falsified documentation, and alleged violations of Russian sanctions.
Key issue: Anti-corruption and sanctions enforcement are increasingly converging.
The cross-Jurisdictional enforcement patterns outlined above highlight the following areas of focus for any compliance or legal professional or Board member of an Israeli company:
• Third-party intermediaries remain the dominant risk vector.
• Public procurement and state-owned entities are high-risk areas.
• Individual liability is expanding.
• Ignored red flags and compliance failures are aggravatingfactors.
• Sanctions and corruption exposure are increasinglyinterlinked.
To address the above and prevent any compliance failures werecommend to:
• Reassess third-party due diligence and commission structures.
• Integrate sanctions and anti-corruption controls into aunified framework.
• Strengthen procurement-focused compliance reviews.
• Ensure documented escalation of compliance concerns.
• Provide board-level visibility into high-risk engagements.
*The contents of this message, current at the date of publication, are for reference and general informational purposes only and do not constitute legal advice. You should contact your attorney to obtain advice with respect to any particular legal matter. You should not act or refrain from acting on the basis of information in this publication without first seeking legal advice from counsel in the relevant jurisdiction. Only your individual attorney can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation.
