Anti-Bribery Compliance in 2025: Key Global Updates
Between regulatory uncertainty in some regions and new rules coming into force in others, 2025 is a critical year for anti-bribery compliance worldwide.
From the UK’s new Failure to Prevent Fraud Offence to the Foreign Corrupt Practices Act (FCPA) enforcement slowdown in the U.S., organizations are struggling to find stable footing on shifting regulatory ground. While enforcement trends are evolving – with some regions increasing scrutiny and others pausing enforcement– anti-bribery laws are still firmly in place.
Companies that assume reduced enforcement means reduced risk may find themselves facing financial penalties, reputational damage, and even criminal charges. To stay one step ahead, take a closer look at the key anti-bribery compliance developments worldwide, along with best practices to stay ahead of their associated risk in 2025.
In this post, we’ll cover the following:
European Anti-Bribery Compliance
Europe remains a global leader in anti-bribery enforcement, with governments introducing stricter regulations and expanding corporate liability.
EU Anti-Corruption Directive
The EU Anti-Corruption Directive is nearing finalization, with negotiations underway between the European Commission, European Parliament, and European Council to finalize its scope. Once adopted, it will require Member States to introduce or strengthen anti-corruption laws, ensuring a more unified and stringent approach across the EU. Key provisions include:
- Corporate Criminal Liability: Companies can be held directly responsible for corruption offenses, not just individuals.
- Expanded Bribery Laws: Covers both public and private-sector bribery, including foreign bribery, for broader enforcement.
- Stricter Sanctions: Fines based on global turnover ensure penalties are severe and proportionate.
- Obstruction of Justice Protections: Criminalizes evidence tampering and retaliation against whistleblowers.
- Lifting Official Immunity: Requires transparent legal process to prosecute corrupt public officials.
With tougher enforcement and harsher policies in the distant future, companies operating across Europe must bolster compliance programs now in order to avoid severe financial and reputational consequences.
Navigating UK Anti-Bribery Laws
UK Bribery Act (UKBA)
The UK Bribery Act (UKBA) remains one of the strictest anti-bribery laws in the world, with a global reach that holds businesses accountable for both domestic and international misconduct. With fraud making up around 40% of all crime in England and Wales, authorities are intensifying enforcement, making corporate compliance more critical than ever.
The UKBA covers:
- Bribery of Foreign and Domestic Officials: Prohibits offering, giving, or receiving bribes, ensuring accountability beyond UK borders.
- Failure to Prevent Bribery: Companies can be held criminally liable if they do not have “adequate procedures” to prevent bribery within their organization or supply chain.
- Corporate and Individual Liability: Both companies and executives can face unlimited fines, criminal prosecution, and up to 10 years in prison.
- Global Jurisdiction: Applies to any company with UK operations, regardless of where the bribery occurs.
Non-compliance can also lead to being banned from government contracts, irreversible reputational damage, and increased regulatory scrutiny, making robust anti-bribery measures a business imperative for companies with UK operations.
Failure to Prevent Fraud Offence
Set to take effect September 2025, the Failure to Prevent Fraud Offence expands corporate liability beyond the UK Bribery Act, targeting a broader range of fraudulent activities. Companies can be held criminally liable if they fail to prevent fraud committed by employees or third parties on their behalf.
“Fraud is a pernicious crime, and we are determined to root it out wherever it takes place. This guidance marks the first steps towards a corporate culture shift around fraud prevention.”
Lord David Hanson
Minister with Responsibility for Fraud
The Failure to Prevent Fraud Offence will:
- Broaden Corporate Liability: Companies can be prosecuted for failing to prevent fraud, even if senior leadership was unaware of the misconduct.
- Impose Severe Penalties for Non-Compliance: Companies risk unlimited fines, reputational damage, and debarment from government contracts.
- Increase Regulatory Scrutiny: Authorities will expect businesses to take a more active role in detecting and mitigating fraud risks.
This legislation marks a major regulatory shift. The best, and really only, defense against fines under this act is proof that reasonable fraud prevention procedures were in place — making proactive compliance a non-negotiable.
U.S. Anti-Bribery Compliance
As U.S. enforcement policies shift, businesses must navigate uncertainty in anti-bribery compliance. While the FCPA remains law, a potential slowdown in enforcement raises critical questions — but non-compliance is still a high-stakes risk.
Foreign Corrupt Practices Act (FCPA)
The Foreign Corrupt Practices Act (FCPA) has long been the cornerstone of U.S. anti-bribery enforcement, with regulators aggressively pursuing violations across industries and jurisdictions. However, the recent “review of enforcement” has sent shockwaves through the compliance world.
A slowdown in FCPA enforcement signals a potential shift in priorities, but it does not mean the law has lost its teeth. Companies that assume lower enforcement means lower risk may find themselves dangerously exposed when priorities shift again.
The FCPA covers:
- Bribery of Foreign Officials: Prohibits offering anything of value to foreign officials to gain business advantages.
- Accounting Transparency: Requires companies to maintain accurate books and internal controls to prevent corrupt payments.
- Global Reach: Applies to U.S. businesses and any foreign company that trades on U.S. exchanges or has operations in the U.S.
The SEC still retains civil enforcement authority over the FCPA, meaning companies remain at risk of investigations and penalties even if criminal prosecutions decline. Additionally, the FCPA’s six-year statute of limitations extends beyond the current administration, meaning that companies can still face enforcement actions long after policies change. FCPA violations continue to carry significant financial penalties, reputational damage, and the risk of criminal liability.
Foreign Extortion Prevention Act (FEPA)
At the same time, the Foreign Extortion Prevention Act (FEPA) — which criminalizes the demand side of bribery by foreign officials — introduces a new layer of complexity. While the FCPA has historically targeted companies and individuals paying bribes, FEPA aims to hold foreign officials accountable for soliciting bribes.
Key takeaways from FEPA:
- Targets Bribery Solicitation: Foreign officials who demand or accept bribes can now face legal action, strengthening global enforcement.
- Expands U.S. Enforcement: Closes a major gap by holding both sides of bribery accountable.
- Raises Corporate Risk: Companies may need to navigate complex diplomatic and legal challenges when dealing with foreign officials.
The combined force of the FCPA and FEPA means companies must remain vigilant, strengthen due diligence, and reinforce ethical business practices to mitigate risk both domestically and globally.
Asia-Pacific Anti-Bribery Compliance
As global enforcement patterns shift, the Asia-Pacific region continues to tighten anti-bribery and corruption laws, reinforcing corporate accountability and financial transparency.
Singapore’s Corporate Service Providers Act (CSP)
In Singapore, recent amendments to anti-bribery and financial crime laws reflect a tougher stance on corporate misconduct. The Corporate Service Providers (CSP) Act and the Companies, Limited Liability Partnerships, and Other Bodies (Miscellaneous Amendments) Act (CLLPMA) introduce stricter regulations for corporate service providers, focusing on anti-bribery, corruption, and money laundering. These laws aim to increase transparency, enhance due diligence requirements, and strengthen enforcement measures, ensuring that businesses operating in Singapore uphold high compliance standards.
Key Provisions from the CSP:
- Stricter Licensing Rules: Requires all corporate service providers to be registered and meet compliance standards.
- Enhanced Due Diligence: Mandates stronger checks on clients to prevent money laundering and illicit activities.
- Tighter Regulatory Oversight: Expands enforcement powers to monitor and penalize non-compliance.
India’s Prevention of Corruption Act (PCA)
Meanwhile, India’s Prevention of Corruption Act (PCA) continues to be actively enforced, with authorities ramping up investigations into both public and private sector corruption. The law criminalizes bribery in both giving and receiving illicit payments, and recent high-profile enforcement actions signal a commitment to cracking down on corporate corruption. With increased scrutiny on foreign companies operating in India, businesses must ensure robust internal controls, third-party due diligence, and whistleblower mechanisms to mitigate bribery risks.
Key Takeaways from the PCA:
- Global Enforcement Reach: Strengthens India’s alignment with international anti-corruption frameworks.
- Burden of Proof Shift: Requires accused individuals and businesses to prove their innocence.
- Corporate Liability: Holds companies accountable for failing to prevent bribery within their operations.
- Stricter Penalties: Increases fines and prison terms for corruption-related offenses.
Compliance Best Practices for 2025
A proactive approach to anti-bribery compliance is a matter of necessity in 2025. While some jurisdictions experience shifting enforcement priorities, others tighten the proverbial net. Either way, strengthening internal policies, enhancing reporting mechanisms, and ensuring company-wide awareness are essential to mitigating risks.
Now is the time for a proactive approach, which should include:
- Reviewing and updating your anti-bribery policies to align with evolving regulations.
- Enhancing employee training to reinforce ethical decision-making.
- Strengthening ethics hotlines to encourage confidential reporting.
- Bolstering third-party due diligence to mitigate bribery risks in your vendor ecosystem.
Anti-Bribery Compliance is a Non-Negotiable
Anti-bribery laws remain firmly in place worldwide and the risks of non-compliance are as high as ever. Lower enforcement levels do not eliminate risk, as companies can still be subject to criminal charges, reputational harm, and fines.
A strong compliance program isn’t just about avoiding penalties — it’s about protecting your business, your reputation, and your future. Stay ahead of global anti-bribery risks by ensuring your compliance program is airtight in 2025 and beyond.
