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Internal controls must be tailored, proportionate, and risk-based — not just a “paper exercise”.

By Erin Brown Jones, Clare Nida, and Matthew Unsworth

Last week, the UK Serious Fraud Office (SFO) published its updated “Guidance on Evaluating a Corporate Compliance Programme” (the Guidance). The agency’s previous guidance was published in 2020 as an eight-page segment in the SFO Operational Handbook. The latest iteration is very much public-facing, with a helpful FAQ section and updates to reflect the “failure…

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The report covers the private law issues that may arise when firms use AI to assist, or directly execute, market activities.

By Nell Perks

In late October, the Financial Markets Law Committee (FMLC) released a report that considers the private law issues that may arise from the use of artificial intelligence (AI) in wholesale financial markets.1 The report offers non-binding guidance on how to conceptualise AI’s impact in private law domains. While the technology may be revolutionary, the FMLC…

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The Court also found limited trademark infringement and seemingly departed from EU law.

By Sophie Goossens and Brett Shandler

On 4 November 2025, the High Court of England and Wales (the Court) handed down its long-awaited judgment in Getty Images v. Stability AI, a case brought by various entities in the Getty Images group as well as a contributor entity (collectively, Getty), essentially alleging that Stability AI had infringed IP rights asserted by Getty in the course of the…

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Landmark decision means companies can assert legal advice privilege against their shareholders in litigation before the English courts.

By Oliver Middleton, Nell Perks, and Alice Zhou

On 24 July 2025, the Privy Council handed down its decision in Jardine Strategic Ltd v. Oasis Investments II Master Fund Ltd and Others (No 2) (Bermuda) [2025] UKPC 34 (Jardine),abolishing the so-called “Shareholder Rule” exception to legal advice privilege as a matter of both Bermudian and English law. The…

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Final report recommends the digitisation of UK shareholdings through a fully intermediated system of shareholding, with an interim phase of digitised share registers.

By Mark Austin CBE, James Inness, Anna Ngo, and Johannes Poon

On 15 July 2025, the Digitisation Taskforce, chaired by Sir Douglas Flint, published its final report, marking a significant milestone in the journey towards digitising the UK shareholding framework. Its findings have been welcomed by HM Treasury on behalf of the UK…

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UK membership will strengthen cross-border enforcement of English court judgments and reinforce London’s position as a key global centre for dispute resolution.

By Oliver Middleton, Samuel Pape, and Sean Newhouse

On 1 July 2025, the Hague Judgments Convention 2019 (Hague 2019) enters into force across the UK for proceedings commencing on or after that date.1 This is a major development in the cross-border enforcement landscape, supporting the recognition and enforcement of English court judgments across a growing…

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In the next phase of Online Safety Act implementation, children’s safety duties and related codes of practice will come into full effect on 25 July 2025.

By Gail Crawford, Fiona Maclean, Alain Traill, Calum Docherty, Edgar Lee, and Amy Smyth

The UK Online Safety Act (OSA) establishes an extensive regulatory framework designed to protect children and adults online by phasing in duties of care on covered service providers, including duties to prevent the spread of…

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The guidelines confirm that FCPA enforcement will continue but provide opportunities for foreign authorities to lead where US interests are not significantly impacted.

By Clare Nida, Pamela Reddy, Nathan H. Seltzer, Annie Birch, and Emma Bunting

On 9 June 2025, US Department of Justice (DOJ) Deputy Attorney General Todd Blanche issued a memorandum outlining guidelines (the Guidelines) for investigations and enforcement actions brought by DOJ under the Foreign Corrupt Practices Act (FCPA). This follows on from…

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The proposed legislation will bring cryptoassets into the full scope of UK financial services regulation and enable the UK’s future cryptoasset regime.

By Stuart Davis and Gabriel Lakeman

On 29 April, UK Chancellor Rachel Reeves unveiled draft legislation aimed at regulating cryptoassets at the International Fintech Growth Summit (IFGS) in London, sponsored by Latham & Watkins.

The proposed legislation will bring cryptoassets (including stablecoins) and cryptoasset-related activities in scope of the UK regulatory perimeter, providing the fundamental legislative framework for the UK’s future financial services regime for cryptoassets. When implemented, firms issuing stablecoins, operating cryptoasset trading platforms, and providing custody, brokerage, or dealing services will require full authorisation to conduct activity in the UK.1

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The updated guidance puts a heavy emphasis on self-reporting and clarifies how corporates under investigation can earn cooperation credit from UK prosecutors.

By Pamela Reddy, Clare Nida, Annie Birch, and Matthew Unsworth

On 24 April 2025, the UK Serious Fraud Office (SFO) published a long-awaited update to its Guidance on Corporate Co-operation and Enforcement (the Guidance). The Guidance outlines the agency’s key considerations when deciding whether to prosecute a corporate or invite it to negotiate a deferred…