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    Feb. 11, 2026

2026 U.K. Enforcement Outlook: Compliance Evaluation Guidance

Shifts in U.S. corruption enforcement priorities, tactics and appetites dominated headlines in 2025, but they were not the only signs of adaptation. The U.K. has seen its own developments, with further movement expected in 2026. In November 2025, the SFO issued Guidance on Evaluating a Corporate Compliance Programme (GECCP) and, in December, the U.K. Home Office published the UK Anti-Corruption Strategy 2025 (Strategy). Then, in a surprise move in January 2026, Nick Ephgrave, head of the SFO, announced that he will retire about half-way through what was supposed to be a five-year term, leaving the future of SFO enforcement uncertain. This first article in a two-part series examining U.K. enforcement developments analyzes the GECCP and what it means for companies. The second article will cover the Strategy and staffing changes at the SFO. See our two-part series on the SFO’s Co‑Operation Guidance: “A Hard Sell for Self-Reporting” (May 21, 2025), and “Investigation Expectations” (Jun. 4, 2025).

A Typical Bribery Fact Pattern Leads to a Quick Guilty Verdict for Rovirosa

The prosecution of Mexican national Ramon Alexandro Rovirosa Martinez is notable for being one of the DOJ’s first FCPA enforcement actions after the issuance in June 2025 of new guidance on how the law will be enforced. While the underlying facts amount to a “typical” bribery pattern, the case illustrates how the DOJ can meet its dual goals of protecting U.S. businesses and pursuing individual violators. The Anti-Corruption Report spoke with attorneys in both the U.S. and Mexico, including former prosecutors in both countries, to understand the implications of the verdict. See “2025 in Review: DOJ Perspectives on How the Blanche Memo Restarted FCPA Enforcement” (Jan. 14, 2026).

International Views on the Role of AI in Compliance Investigations

The use of AI systems is transforming the way that compliance investigations are conducted, but it also raises issues of ethics, transparency and accountability in algorithmic decision-making. During a panel discussion at the New York City Bar’s International White Collar Crime Symposium 2025, international experts discussed these issues and offered guidance on how compliance professionals can best use AI, including agentic AI tools, and provided best practices for interacting with regulators. This article summarizes their insights. See “Benchmarking AI Uptake by Compliance Functions” (Dec. 3, 2025).

A Quick Start Guide to Click-Through Training

Live, in-person trainings are considered the gold standard for employee learning, but most companies now use some form of prerecorded and asynchronous education programs. These “click-through trainings” can be delivered to a broad audience that only has to click through screens and multiple-choice tests to complete the training. Click-through training has significant advantages over traditional training methods and can be a powerful tool for keeping a large and far-flung workforce informed, but getting the most out of it requires thoughtfulness and planning. This quick start guide sets forth the basics of how to fit bite-sized learning experiences into a broader training program. For a more detailed discussion, see our three-part series “Rethinking Click-Through Training”: The Pluses and Minuses (Feb. 26, 2025), Maximize Effectiveness With Customization (Apr. 9, 2025), and Integration Into a Comprehensive Training Program (May 7, 2025).

Benchmarking Fund Managers’ Adoption and Governance of Generative AI

AI – and generative AI (Gen AI) in particular – is being incorporated at an unprecedented rate into virtually all areas of the economy. Thus, it is not surprising that virtually all fund managers who participated in a study conducted by the Alternative Investment Management Association (AIMA) said they use Gen AI in their work – and most are increasing their use. Earlier this year, AIMA asked fund managers about their uptake of Gen AI, including their approaches to governance, policies and procedures, risks and limitations of Gen AI, training and hiring, Gen AI models, and use cases. It also asked institutional investors about their AI-related concerns and communications with fund managers. This article distills the key takeaways from AIMA’s study. See “A Baker’s Dozen AI Governance Resolutions for 2026” (Jan. 14, 2026).

Jane Norberg Joins Ogletree Deakins As Co‑Chair of Whistleblower and Compliance Group

Ogletree Deakins has welcomed Jane Norberg, former Chief of the SEC’s Office of the Whistleblower, to the firm’s Washington, D.C., office, as a shareholder and co-chair of the whistleblower and compliance practice group. She arrives from Arnold & Porter. For commentary from Norberg, see “NAVEX Study Finds Incident Reporting Steady, But Substantiation Rates Rising” (May 7, 2025).

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Women to Watch: Contributions, Achievements and Observations of Outstanding Female Professionals

To mark International Women’s Day, women editors and reporters at ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Law Report Group editors Jill Abitbol, Robin L. Barton and Megan Zwiebel profile notable women in data privacy, cybersecurity, private funds and anti-corruption law, including Anne-Gabrielle Haie, Jessica Lee, Micaela McMurrough, Laura Perkins, Amanda Raad, Madelyn Calabrese, Ranah Esmaili and Genna Garver. Enjoy reading their inspiring remarks here.