UK Regulators Accelerate Enforcement of Economic Crime Legislation in 2026

UK financial regulators are moving beyond signalling intent to actively enforcing the Economic Crime and Corporate Transparency Act 2023 (ECCTA), with enforcement actions accelerating into 2026. Coordinated efforts between HM Revenue & Customs, Companies House, the Insolvency Service, and the Serious Fraud Office are reshaping governance expectations across the financial services sector, according to regulatory analysis reviewed by investigators.

Background and Context

The enforcement landscape shifted fundamentally on 1 September 2025 when the Failure to Prevent Fraud (FtPF) offence came into force under ECCTA. This provision establishes strict criminal liability when representatives commit fraud for an organisation's benefit, removing the comfort firms previously found in relying solely on "reasonable procedures" defence mechanisms. Early enforcement activity began in mid-2025 but has accelerated markedly this year, creating a new regulatory reality for financial institutions.

Key Figures and Entities

Companies House has emerged as a particularly active enforcer, utilising enhanced investigative powers granted under ECCTA to identify and remove fraudulent entities from the UK corporate register. The agency's effectiveness is amplified through multi-agency collaboration, most notably in a recent sweep coordinated by the National Economic Crime Centre that brought together Companies House, HMRC and the Insolvency Service. This joint operation resulted in approximately 11,000 companies being struck from the register, demonstrating authorities' commitment to "cleaning up" the corporate landscape.

Legal and Financial Mechanisms

The Act introduces a significantly expanded senior manager attribution rule that holds organisations criminally liable when wrongdoing can be linked to senior management conduct, even where anti-fraud controls exist. Crucially, the definition of "senior manager" has broadened beyond board members and C-suite executives to include any individual playing a meaningful decision-making role, including senior compliance leaders. This attribution logic extends beyond fraud to offences including money laundering and sanctions evasion, materially increasing both personal and institutional risk exposure.

International Implications and Policy Response

Sanctions compliance underwent structural simplification on 28 January 2026 when the UK government consolidated all designations under the Sanctions and Anti-Money Laundering Act 2018 into a single unified sanctions list. While removing ambiguity about authoritative sources, this consolidation increases expectations that screening and monitoring processes are precise and current. Enforcement capability is being further strengthened through technology under the UK Anti-Corruption Strategy 2025–2030, with the National Crime Agency leading efforts to pursue illicit finance supported by the SFO, Financial Conduct Authority and City of London Police's Domestic Corruption Unit, which is piloting AI-enabled investigation assistants to analyse years of suspicious activity reports in minutes rather than months.

Sources

This report draws on analysis from regulatory compliance specialists, official enforcement announcements, and UK government guidance on the implementation of the Economic Crime and Corporate Transparency Act 2023. Information regarding agency actions and statistics comes from public statements by the National Economic Crime Centre, Companies House, and the National Crime Agency.