Global enforcement shifts in 2025

2025 marks a pivotal year in global bribery and corruption enforcement, with evolving political landscapes driving new regulatory priorities. Hogan Lovells’ latest Bribery & Corruption Outlook highlights key enforcement trends in the U.S., UK, EU, and beyond, underscoring the need for corporations to adapt swiftly to changing frameworks.

“Political shifts could redefine the global enforcement landscape in ways we’ve not seen before,” said , Deputy Head of Investigations, White Collar and Fraud at Hogan Lovells. In the UK, the new Failure to Prevent Fraud offence, effective September, introduces additional compliance obligations for large organisations. Globally, businesses must navigate increasing regulatory complexity while ensuring robust compliance measures.

The report explores the intersection of corporate criminal enforcement and political influence, particularly in the U.S., where Department of Justice (DOJ) policies may shift with new leadership. Companies must prepare for heightened scrutiny and evolving risk factors as enforcement agencies intensify their focus on fraud prevention and corporate accountability.

The rise of whistleblower protections

Regulatory changes across multiple jurisdictions may make 2025 the "Year of the Whistleblower." EU reforms, coupled with increased U.S. attention on disclosures and UK calls for stronger whistleblower protections, place mounting pressure on companies to improve internal reporting mechanisms.

“Governments around the world are continuing to focus on anti-corruption regulation and enforcement,” said Stephanie Yonekura, Head of Investigations, White Collar and Fraud at Hogan Lovells. “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’s growing role in compliance

Artificial intelligence is poised to revolutionise compliance strategies, particularly as the DOJ emphasises AI’s role in regulatory oversight and enterprise-wide data management. Companies leveraging AI-driven compliance programs can enhance efficiency, mitigate risks, and reduce costs.

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

Regional enforcement developments

The report outlines significant regional developments shaping bribery and corruption enforcement in 2025:

• U.S.: The Foreign Extortion Prevention Act (FEPA) introduces new criminal liabilities for foreign officials soliciting or receiving bribes.
• UK: The Failure to Prevent Fraud offence, effective September 2025, presents new compliance risks for large organisations.
• EU: Ongoing efforts to harmonise anti-corruption directives alongside challenges in whistleblower protections.
• APAC & LATAM: Strengthened anti-corruption initiatives in Mexico, Indonesia, Singapore, and Vietnam driven by government reforms and global collaboration.

As corporations face increased scrutiny and evolving legal frameworks, proactive compliance measures and adaptability remain critical to mitigating bribery and corruption risks in 2025.