The opinions expressed here are those of the authors. They do not necessarily reflect the views or positions of UK Finance or its members.

This blog was co-written by Michael Pollitt, Simon Stiggear and Gina Burley-Staffieri, KPMG UK.

With the introduction of new guidance on “reasonable procedures” and another disappointing result for the UK in the Corruption Perceptions Index, many in the world of anti-bribery and corruption (“ABC”) perhaps saw 2024 as a year of history repeating itself. 

So, rather than looking back over the predictable developments of the past year, we’re making things more interesting in this piece, by setting out what we think will be the three “hot topics” in ABC for 2025 – and it’s set to be quite a year. 

Hot Topic 1: Anti-corruption priorities for the new government 

There were (at least) three anti-corruption presents on many of our Christmas lists for 2024. A commissioner, a champion and a strategy.

Well, someone must have been listening, as two out of three gifts have been delivered in the form of Tom Hayhoe and Margaret Hodge who have been appointed as the as the new Covid anti-corruption commissioner and anti-corruption champion, respectively. 

Hayhoe’s tasks include examining an estimated £7.6bn of Covid-related fraud in the hope that £2.6bn can be recouped from waste, fraud and corrupt contracts signed during the pandemic. Hodge, on the other hand, will be working with Parliament, the private sector and civil society to drive the new government’s anti-corruption agenda. 

So, it seems the players are ready, but we still eagerly await the arrival of a new UK anti-corruption strategy, which will surely direct Hodge’s 2025 gameplan, especially when it comes to private sector enforcement. The strategy, we hope, will be based on practical, achievable, realistic outcomes, which recognise the role of all stakeholders in combatting corruption.

Hot Topic 2: Reinvention of the ABC practitioner’s role 

ABC-specialists can expect to find themselves as an in-demand resource in 2025, as organisations prepare for the latest corporate criminal offence, on “failure to prevent fraud”. 

With an effective date of 1 September 2025, organisations will have eight months to demonstrate “reasonable procedures”, which will act as a defence were they to be pursued under the new offence. 

In terms of designing and implementing these procedures, leaders are turning to ABC specialists for guidance, given their experience of implementing “adequate procedures” in response to the UK Bribery Act.

Practically, ABC specialists should prepare themselves for the following questions: 

• What worked well when you were implementing “adequate procedures” to prevent bribery? 
• How would you change your approach if you were preparing for a new “failure to prevent” offence?
• Which ABC procedures could be leveraged for preventing fraud?

Then, taking things one step further, ABC specialists could find themselves owning their organisation’s response to “failure to prevent fraud”. If they do, they should upskill in the underlying offences which could trigger a “failure to prevent fraud” offence and understand how particular fraud typologies (e.g. fraudulent ESG reporting, rogue trading and mis-selling) could materialise in their organisation.

Hot Topic 3: A chance for governments around the world to prove themselves on corruption 

2024 was the biggest election year in history. Nearly half of the world’s population – some 3.7 billion people – were given an opportunity to go to the polls in 72 countries. 

And if 2024 was a year of elections, 2025 will be a year of new and returning governments. 

In situations like this, a strong anti-corruption agenda has long been used as a way for newly elected parties to set themselves apart from their predecessors, correct old mistakes, and re-establish public trust. 

After assuming power in 2017, for example, Emmanuel Macron introduced a wave of reforms designed to counter corruption in French politics and bring about a “moralisation” of the public sector. Likewise, in 2021, his inaugural year as president, Jo Biden issued the first US Strategy on Countering Corruption “to meet the grave threat transnational corruption poses to US national security”. 

If these policies remain towards the top of the “to-do” list for new administrations, the sheer number of new and returning governments worldwide could make 2025 a very interesting year for the ABC agenda – with more rhetoric, pledges, strategies, policies and (by extension) enforcement than ever before. 

Firms should therefore ensure that their risk assessments reflect, not only changes in their inherent risk environment, but also this broader re-prioritisation of bribery and corruption as an area of global enforcement. 

What happens next 

Whatever happens in 2025, it’s certainly due to be an interesting ride. The challenge for private actors will be to ensure that their ABC programme can respond to these predictions – as well as adapting to the unpredictable.