On 20 March 2025, the UK Serious Fraud Office (SFO), the Attorney General of Switzerland (AGS) and the Parquet National Financier of France (PNF) announced that together they had formed the International Anti-Corruption Prosecutorial Taskforce [1] (ACP Taskforce).
The ACP Taskforce members underlined their commitment to tackling the “significant threat of bribery and corruption” within existing national and international legal frameworks and confirmed the creation of the Leaders Group to facilitate “a regular exchange of information, insight and strategy” and a Working Group “for the purpose of devising cooperation on cases, increased best practice sharing and a strengthened foundation for operational collaboration.”
The announcement also stated that ACP Taskforce were going to invite other agencies involved in fighting international bribery and corruption to join the ranks by way of signing a mutual agreement.
The creation of the ACP Taskforce is particularly significant in the context of the current pause on US anti-corruption enforcement efforts announced in the US Department of Justice (DoJ) Executive Order of 10 February 2025 [2] – the move interpreted by many as the end of the anti-corruption enforcement era.
The question remains as to whether the ACP Taskforce can fill the shoes of the DOJ, which has historically been the most feared enforcement authority in the anti-corruption arena. Given that 9 out of 10 largest US Foreign Corrupt Practices Act cases have been instigated against non-US companies [3], there seems little reason why coordinated action by the European agencies cannot be effective.
The choice of the ACP Taskforce members is also significant, as information sharing between the UK, France and Switzerland has long been difficult due to the French Blocking Statute and Swiss Banking laws. During the investigation of Airbus in 2017 – 2020, the PNF and SFO created the first Joint Investigation Team (JIT) for economic crime. It allowed for information and evidence to be shared between the two authorities under certain agreed conditions. The ACP Taskforce Leaders and Working Groups seemingly provide for regular and increased collaboration between the members, without the constraints of relevant blocking and secrecy laws.
An enforcement resurgence: United Insurance Brokers Limited
On 17 April 2025, the SFO announced [4] that it had charged United Insurance Brokers Ltd (UIBL) with Failure to Prevent Bribery, under section 7 of the Bribery Act 2010. To further emphasise its continued focus on prosecuting corruption, the agency Director Nick Ephgrave that said:
‘The SFO remains committed to stamping out international bribery wherever it may occur.
British companies have a duty to prevent the harm caused by bribery when doing business at home and abroad, to ensure that the UK remains a safe and fair place to do business.’
Although UIBL is a UK-based company, the case against it involves cross border corruption. According to the SFO press release [5], UIBL is accused of failing to prevent bribery of an official in Ecuador by its US based intermediaries, in exchange for USD38m re-insurance contracts.
Companies and individuals falling within the broad extraterritorial reach of the Bribery Act 2010 and its equivalent French [6] and Swiss anti-corruption laws [7] should therefore be mindful that whilst anti-corruption enforcement may currently be down, it is certainly not gone for good.
Updated: 17 April 2025
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[1] https://assets.publishing.service.gov.uk/media/67dc0bb3931ea30d1b7ee33d/International_Anti-Corruption_Prosecutorial_Taskforce.pdf
[2] https://www.whitehouse.gov/presidential-actions/2025/02/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/
[3] https://fcpa.stanford.edu/statistics-top-ten.html (Odebrecht ($3.6bn), Airbus ($2.1bn), Petrobras ($1.8bn). Ericsson ($1.3bn), Telia ($965m), MTS ($850m), Siemens ($800m), VimpelCom ($795m) and Alstom ($772m))
[4] https://www.gov.uk/sfo-cases/united-insurance-brokers-limited
[5] https://www.gov.uk/government/news/uk-insurer-charged-with-bribery-in-ecuador
[6] Sapin II
[7] Swiss Criminal Code.