Financial Crime 2026

Financial Crime: A General Overview

I am delighted to present the first edition of the Chambers Financial Crime Global Practice Guide. I would like to thank all those who have responded to my questionnaire and for their contributions and articles which have been included in this Guide.

In 2026, financial crime will continue to represent a systemic risk at a global level, driven by digitalisation, cross-border payment flows and the increasing sophistication of organised criminal networks. According to estimates by the United Nations Office on Drugs and Crime, financial crime and related illicit financial flows account for approximately 2–5% of global GDP, equivalent to between USD2 trillion and USD5 trillion annually. The World Economic Forum has further identified fraud as the single fastest-growing crime type worldwide, outpacing drug trafficking and cyber-dependent crimes in year-on-year growth.

Financial crime is consistently evolving and becoming even more sophisticated and difficult to detect. Driven by AI technology, geopolitics and consumer behaviour, the cost to the global economy is severe. Some estimates suggest financial crime, including money laundering, costs the UK (for example) around GBP14 billion annually.

Regulators are now demanding even stronger governance, accountability and scrutiny for professional institutions and advisers such as banks, lawyers, accountants, fintechs and corporate service providers to assist in combatting financial crime. In addition, new legislation and enforcement have been introduced both in the UK and globally to deal with this pervasive crime.

This 2026 Chambers Financial Crime Global Practice Guide is devised and drafted to assist those in business, both individuals and corporations, to navigate this evolving terrain.

The Guide has sought analysis and opinion from leading practitioners around the world to provide practical and informative advice in respect of the regulation and enforcement of financial crime and to share their insight into future developments in this area.

It is clear from the analysis compiled that financial crime investigations and enforcement are not globally uniform. Developments in different jurisdictions are not guaranteed to be adopted universally; however, some broad shared issues do exist.

Global developments and reforms for combatting financial crime

UK

A global challenge in recent years has been how the law has developed to combat financial crime. Countries have looked at introducing new legislation in their individual jurisdictions to explore ways to disrupt fraudsters. This type of fraud prevention has also become a top priority in the UK. The following is a summary of the efforts the UK is making to combat financial crime.

In March 2026, the Government released “Fraud Strategy 2026-2029 Disrupting crime, supporting economic resilience and delivering justice”. This report, amongst other recommendations, highlights the government’s approach to disrupting crime and encouraging enforcement agencies to support intelligence sharing and collaboration to detect fraud early and to strengthen governance and international partnerships.

In addition, in April 2026 the National Crime Agency (NCA) launched a new Online Crime Centre (OCC), alongside the Home Office which connects the data expertise and knowledge of the City of London Police, Government Communications Headquarters (GCHQ), National Cyber Security Centre (NCSC) and National Cyber Force (NCF) as well as international law enforcement to collaborate and tackle financial crime.

The NCA, as part of Operation Machinize, continues its nationwide campaign to crack down on and target cash businesses used as a cover for fraud and money laundering.

The Serious Fraud Office (SFO) recently announced that it is prioritising enforcement of the “failure to prevent fraud” offence under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), holding large organisations accountable for employee-level fraudulent acts. The Act also introduced measures relating to reforms in identifying crypto-assets and relating to money laundering and, most significantly, reforms to Companies House. ECCTA has provided Companies House with the ability to expand its powers to verify directors’ identities, query suspicious filings and strike off dormant and/or fraudulent entities. This has been hailed as the most substantial transformation in corporate regulation the UK has seen in decades.

The Financial Conduct Authority (FCA) has now become the single supervisor for AML/CTF for professional services including lawyers and accountants. The Insolvency Service has also announced its strategy for tackling economic crime by expanding its investigative and prosecutorial functions and working closely with Companies House and HMRC through a referral relationship in co-ordination with the National Economic Crime Centre (NECC).

The City of London Police’s Domestic Corruption Unit is piloting state-of-the-art, AI-enabled “corruption investigation assistants” to assist the regional and local police and speed up investigations.

These UK domestic reforms coincide with reforms in other jurisdictions across the globe. The trend is familiar. Combatting financial crime requires more accountability and more governance by corporations.

USA

The USA has always seemed to be at the forefront of legislative reform to tackle financial crime, and other countries have followed suit.

Recent reforms include the False Claims Act, which has prioritised financial crime and white-collar crime enforcement, particularly in relation to healthcare fraud, government contracting, tariffs and customs duties. The US administration has prioritised holding company executives and employees accountable for fraud, which is similar to the UK’s “failure to prevent fraud” offence under the ECCTA.

The US DOJ has also recently revised its Foreign Corrupt Practices Act (FCPA) guidance and amplified its collaboration with its European counterparts through a new task force and its recent accession to the International Anti-Corruption Coordination Centre. The FCPA seeks to target conduct that directly undermines US national interests and to pursue those suspected of bribery “that facilitates the criminal operations of Cartels and [transnational criminal organisations]”. This extends to potential companies operating in “Territories dominated by Cartels, criminal gangs, and other transnational criminal organisations” that “threaten the erosion of their rule of law and economic growth”.

Greece

In order to deal with financial crime, Greece has recently updated its legislation to focus on compliance, making “obliged entities” report suspicious activities and comply with detailed KYC due diligence to the Anti-Money Laundering Authority. A failure to do so could involve significant fines and even being held liable as an accomplice. Updated legislation in relation to combatting tax evasion has also been a recent priority for this jurisdiction.

Portugal

Likewise, Portugal has undergone recent development to its legal framework to align with its European neighbours in respect of the prevention of corruption. Its Anti-Corruption Strategy for 2025–2030 seeks to entrench a culture of transparency and accountability. Its Regime Geral de Prevenção da Corrupção (RGPC) marks a significant advance towards a more co-ordinated and preventive anti-corruption framework, adopting more robust compliance systems.

Switzerland

Switzerland has also undertaken several significant legislative and reform initiatives in financial crime. The revision of the Anti-Money Laundering Act (AMLA), which has been under discussion for several years, and is expected to enter into force in the second half of 2026, aims to extend AML obligations to certain non-financial sector activities, including the real estate sector and the advisory services of lawyers.

The proposed amendments also seek to strengthen beneficial ownership transparency requirements. The reform process has generated considerable debate within the legal profession, particularly regarding the balance between transparency objectives and professional secrecy.

Croatia

Croatia is also undergoing significant reforms to combat fraud and bribery. It is expected to become a member of the OECD (Organisation for Economic Co-operation and Development) during the first half of 2026.

The OECD is an intergovernmental organisation of 38 member countries committed to democracy and the market economy. Headquartered in Paris, France, its primary mission is to promote policies that improve the economic and social well-being of people worldwide. It operates as a kind of “soft law” regulator, albeit one with a particularly strong practical effect. Its recommendations, guidelines, and conventions, although not always formally binding, create standards whose implementation becomes de facto necessary for states seeking full integration into global economic flows.

In the field of financial and economic crime, the OECD has developed a normative framework based on several key principles:

• transparency in business and in the public sector;
• accountability of legal entities and natural persons;
• effective enforcement of criminal legislation; and
• international co-operation and exchange of information

Singapore

Singapore is also in the midst of legislative changes to combat fraud through major governance reform. This has recently been highlighted following the ongoing trial relating to the Hyflux case. This case involves corporate failure and signals a fundamental shift in the country’s approach to corporate accountability and disclosure enforcement. The legal implications are likely to affect all enterprises operating in Singapore’s capital markets. The legislative reforms are likely to enhance the requirement of proactive compliance, executive accountability and governance evolution.

Global investigations and co-operation

UK

In recent years the UK has surprisingly seen a decline in the number of major global investigations it is involved in.

That said, the SFO has set out its 2026 strategies for tackling global crime which include:

• increasing international co-operation and collaboration with international law enforcement agencies to investigate more cross-border frauds;
• implementing a proactive technology-driven approach and using AI to accelerate investigations and detect early indicators of fraud;
• working with the International Anti-Corruption Prosecutorial Taskforce, involving the French Financial Prosecutor (PNF) and Swiss Office of the Attorney General, to tackle multi-jurisdictional bribery; and
• focusing on investigating crypto-related money laundering and fraud.

The above strategy for 2026 seems to suggest that law enforcement agencies in the UK are gearing up for an inevitable rise in global and joint investigations. Only time will tell.

USA

The USA takes extraterritorial financial crime very seriously. US law enforcement has consistently advocated for global co-operation to assist in sharing information with investigators.

There are a number of tools to assist them in obtaining such evidence. These include mutual legal assistance treaties (MLATs) with many countries that provide a formal, binding, and reciprocal mechanism to request testimony, documents, or bank records located in foreign countries. Authorities may also use letters rogatory, which are applications to a foreign court seeking judicial assistance.

US law enforcement agencies often have agreements with their foreign counterparts to share information and intelligence. For example, the Securities and Exchange Commission (SEC) uses multilateral and bilateral information sharing agreements – often called “memoranda of understanding” or MOUs – to facilitate consultation and co-operation with its foreign counterparts. These MOUs establish clear guidelines and protocols for exchanging information.

Under the Clarifying Lawful Overseas Use of Data (CLOUD) Act enacted in 2018, US authorities can also compel US-based service providers to produce electronic data (emails and texts) pursuant to a warrant, even if such data is stored outside of the United States.

Europe

Similarly in Portugal, international co-operation in matters of financial crime is based on a framework law on international judicial co-operation in criminal matters. This governs extradition, mutual legal assistance (including searches, seizures, asset freezing, and the gathering of evidence), transfer of proceedings, and the enforcement of criminal judgments, operating in conjunction with Council of Europe conventions, United Nations instruments, and European Union instruments.

Regarding money laundering and terrorist financing, the Financial Intelligence Unit of the Criminal Police (Polícia Judiciária) carries out the exchange of information between Financial Intelligence Units and competent authorities of different EU member states, as well as with European co-operative structures such as Eurojust and Europol.

Greece also provides for international co-operation in financial crime matters through both EU mechanisms and international agreements. Within the European Union, co-operation is primarily effected through the European Arrest Warrant, which enables simplified and expedited surrender procedures between member states, as well as instruments of mutual legal assistance and information-sharing (such as the European Investigation Order).

In addition, co-operation is reinforced through institutions such as the European Public Prosecutor’s Office (EPPO), competent for offences affecting the EU’s financial interests, and agencies addressing organised crime, such as Europol.

Beyond the EU, Greece participates in extradition and mutual legal assistance through bilateral and multilateral conventions, including the European Convention on Extradition, as well as agreements with third states (eg, the United States and Australia).

Police co-operation and information exchange are further facilitated through international organisations such as Interpol.

Switzerland has signed numerous international treaties. International co-operation in criminal matters is principally governed by the Federal Act on International Mutual Assistance in Criminal Matters (IMAC). It provides co-operation measures including the service of documents, taking of evidence, search and seizure, and the freezing and handing over of assets. Switzerland also co-operates through INTERPOL and the Egmont Group of financial intelligence units.

For the Republic of Croatia, OECD membership represents an additional incentive to strengthen these mechanisms.

OECD standards emphasise the importance of:

• timely exchange of information;
• mutual legal assistance; and
• co-ordinated investigations.

The rise of aggressive sanctions regimes

The current geopolitical crises across the globe continue to influence the need for aggressive sanctions. For businesses, the importance of adhering to sanctions obligations has never been so crucial. Failing to abide will result in severe penalties for breaches.

In March 2022, following Russia’s invasion of Ukraine, ECCTA was amended to mirror the US enforcement model and enable the Office of Financial Sanctions Implementation (OFSI) to operate on a strict liability basis, meaning it can now penalise companies and individuals for sanctions breaches they may not know they have committed.

In March 2024 the EU’s harmonisation of sanctions evasion became a criminal offence across all member states.

The UK continues to be a target for foreign corruption networks and a place where regulation has intensified for banks, accountants, lawyers, fintechs and corporate service providers.

There is now a closer co-operation between authorities worldwide who share the use of intelligence sources in relation to sanctions enforcement; more so in light of current conflicts.

Cybercrime and cryptocurrency

We now exist in a largely borderless digital world. The rise in cryptocurrency-related fraud is both complex and profound across the globe. The need to tackle this pandemic is at the forefront of policy in all countries and has led to new legislation and enforcement controls.

The UK has seen a spate of landmark rulings that now identify cryptocurrency as property. The rulings also made headway in establishing the location of cryptocurrency within a court’s jurisdiction and place greater obligations on crypto exchanges to identify those involved in crypto-fraud.

The UK is taking cryptocurrency fraud seriously. So much so that last year the UK government set out draft legislation: the Financial Services & Markets Act 2000 (Cryptoassets) Regulation 2025. This is set to become a statutory instrument by 2027. The FCA recently secured a conviction against a person operating illegal cryptocurrency ATMs. There are likely to be more investigations and convictions relating to this type of fraud. Indeed, it is clear that crypto is now firmly within the UK’s regulated sector.

Similarly, the US Department of Justice (DOJ) and SEC have also increased enforcement action such as the recent case of the failed crypto exchange FTX.

Last year the USA passed its first cryptocurrency legislation, namely the GENIUS Act. This sought to establish the legitimacy of cryptocurrency and global tokenisation.

The USA has also prioritised, under the False Claims Act, procurement and government contracting cases where, among other things, contractors are being targeted for failing to meet cybersecurity requirements. The recent prosecution of the Nightwing Group involved a failure to implement adequate cybersecurity controls.

International harmonisation and co-operation

Financial crime is a global crisis. The need to detect and investigate cannot just be carried out domestically. Organised crime groups across the globe are evolving and working in tandem on cross-border frauds. This has prompted greater collaboration between states and the sharing of intelligence and conducting joint investigations. Law enforcement agencies from different jurisdictions are now working more closely than ever before.

Nations around the world are increasingly reliant on the UK for intelligence to tackle financial crime. An example of this is Operation Chakra-V, a joint investigation launched in 2024 involving the NCA, the FBI, Microsoft, and India’s Central Bureau of Investigation, in which authorities raided a call centre in Noida, India, and arrested a gang responsible for scamming victims in the UK, the USA, and Australia through fake tech support scams.

The recent arrests in Nigeria are another example of collaboration between states. In this case it was the UK’s NCA and Nigerian police. The case involved an investment scam using bogus social media accounts to impersonate cryptocurrency traders targeting victims in the UK and USA.

Indeed, as mentioned before, UK law enforcement agencies are making it a priority and part of their strategy to encourage the international sharing of intelligence. The SFO’s 2026 strategy includes actively collaborating with international taskforces for cross-border investigations.

It seems that all nations are harmonising their laws and adhering to the standards of international bodies such as the Financial Action Task Force (FATF) and the OECD Anti-Bribery Convention.

Deferred prosecution agreements (DPAs)

The use of deferred prosecution agreements (DPAs) has become ever more popular across the globe. The USA first introduced them in the 1990s. It took over 20 years for the UK to follow suit when they were introduced under Schedule 17 of the Crime and Courts Act 2013.

A DPA is an agreement reached between a prosecutor and an organisation which could be prosecuted, under the supervision of a judge. The agreement allows a prosecution to be suspended for a defined period, provided the organisation meets certain specified conditions. DPAs can be used for fraud, bribery and other economic crime. They apply to organisations, never individuals.

The key features of DPAs are that they:

• enable a corporate body to make full reparation for criminal behaviour without the collateral damage of a conviction;
• are concluded under the supervision of a judge, who must be convinced that the DPA is “in the interests of justice” and that the terms are “fair, reasonable and proportionate”;
• avoid lengthy and costly trials; and
• are transparent, public events.

UK

To date, the SFO has entered into 13 DPAs, but none since the 2023 agreement between the Crown Prosecution Service and Entain plc for a failure to prevent bribery. The corporation agreed to pay over GBP615 million in reparation over a four-year period.

The benefits of DPAs to resolve corporate misconduct liability have made them attractive to other nations.

USA

In the USA, the government may decline or defer prosecution after considering the evidence relevant to the financial crime. While the circumstances of a non-prosecution or deferred prosecution agreement are case-specific, the government typically enters into these agreements where the defendant has voluntarily and promptly disclosed its misconduct, co-operated with the government’s investigation, and engaged in remedial steps.

Europe

France was inspired to introduce the Convention Judiciaire d’Intérêt Public, which is a similar model to the DPA and concluded its first one in 2017. Singapore did the same when they introduced the Criminal Justice Act in the same year, with Canada, Japan and Argentina following suit.

Following the introduction in Singapore of the Criminal Justice Act, financial crime plea discussions may occur between the accused and the public prosecutor, but any private “plea agreements” are not specifically enforceable. Deferred or non-prosecution agreements are available in certain circumstances but extremely rare.

In Portugal there is a similar provision to a DPA. A central instrument of consensual resolution is the provisional suspension of proceedings (suspensão provisória do processo), whereby the public prosecutor proposes the suspension, subject to the defendant’s acceptance of certain obligations - such as payments or regularisation measures – with the agreement of both the injured party and the judge. Upon full compliance with such obligations, the proceedings are ultimately discontinued. However, recourse to this mechanism is only permissible at the early stages of criminal proceedings and only in respect of offences punishable with no more than five years’ imprisonment. In offences such as corruption, embezzlement, and money laundering, provisions of a “reward-based” nature exist, whereby decisive co-operation with the authorities and the restitution of illicit advantages may result in a waiver of penalty or significant mitigation.

Although there is no broad system of plea bargaining, the combination of mechanisms, such as regularisation, co-operation, provisional suspension, and waiver or mitigation of penalties, effectively enables negotiated solutions and significant reductions in sanctions within the Portuguese legal system.

In Greece, however, DPAs are not available. Criminal negotiation (Article 303 of the Code of Criminal Procedure) may be initiated upon request of the defendant or at the initiative of the prosecutor at any stage prior to the commencement of the evidentiary proceedings before the trial court, in exchange for a confession and a reduced sentence. The relevant agreement is drawn up in writing and must be ratified by the court. If no agreement is reached, the criminal proceedings continue from the stage at which they were interrupted, and any written request by the defendant or invitation by the prosecutor is destroyed and cannot be used against the defendant. Time will tell whether legislative reforms provide for DPAs in Greece in the future.

Similarly, Switzerland does not have deferred prosecution agreements or non-prosecution agreements under its domestic law. Although the Office of the Attorney General of Switzerland proposed introducing a DPA-like mechanism during the 2022 revision of the Criminal Procedure Code, the Federal Council rejected the proposal. At present there is no statutory framework allowing prosecutors to enter into negotiated settlement agreements with companies or individuals in exchange for compliance undertakings or monitorship arrangements.

Self-reporting and whistle-blowers

Corporations are incentivised to enter into DPAs to avoid criminal prosecution. To benefit from such agreements, they must have effective self-reporting and whistle-blowing procedures in place. Additionally, conducting a robust internal investigation is of paramount importance.

UK

The SFO’s revised Corporate Cooperation Guidance published in April 2025 gave a clear assurance that DPA negotiations will follow prompt self-reporting “unless exceptional circumstances apply”. Whistle-blowing in the UK is a procedure for the reporting of workplace wrongdoing such as fraud or other legal breaches which are in the public interest.

Whistle-blowers are protected from dismissal or detriment under the Public Interest Disclosure Act 1998 if they make a “qualifying disclosure” to their employer, a regulator, or other prescribed bodies.

Many commentators have advocated for the introduction of incentive arrangements for whistle-blowers in the UK. The UK Government has now acknowledged this and in its Anti-Corruption Strategy, published in December 2025, there is a commitment to exploring the viability of these arrangements. HMRC have recently explored a Strengthened Reward Scheme which may provide a template for how such a scheme could operate in the UK.

Any financial incentive is likely to increase the number of whistle-blowers coming forward. This scheme will no doubt also lead to more disclosures of corporate wrongdoing, but this may also come with its own issues.

USA

The USA has used this whistle-blowing provision for a while and have in place a very attractive financial incentive for whistle-blowers to come forward. In 2024, DOJ’s Criminal Division introduced a Corporate Whistleblower Awards Pilot Program (the “Whistleblower Program”) designed to incentivise tips from whistle-blowers to uncover corporate crime. Under the programme, any whistle-blower that provides the Criminal Division with original and truthful information about corporate misconduct that results in a successful forfeiture of assets may be eligible for an award. Thus, the bargain is simple – if the whistle-blower reports corporate misconduct, and the tip results in a prosecution and forfeiture, then the whistle-blower may receive a financial award.

The programme permits the whistle-blower to submit his or her tip anonymously through a lawyer. However, even if a whistle-blower reports conduct without a lawyer – and is thus required to disclose his or her identity to DOJ – there are assurances that DOJ will protect the confidentiality of the whistle-blower except as required by law or some other compelling need or interest.

In May 2025, DOJ expanded the Whistleblower Program, which was first created in 2024, to broaden the array of offences eligible for awards. While the original pilot programme covered financial institution crimes, foreign bribery, domestic bribery and kickbacks, and healthcare offences, the expanded programme now encompasses procurement and federal programme fraud, trade and customs fraud, federal immigration violations, and support for foreign terrorist organisations, cartels, and transnational criminal organisations.

Unsurprisingly, these additional offences eligible for an award under the programme directly reflect the priorities of the current administration. This expansion appears to have yielded fruitful results. In September 2025, DOJ reported that since the expansion, it had received 313 tips and found that 120 of them warranted additional investigation, “including a number of tips relating to priority areas – procurement fraud, trade fraud, and sanctions evasion”.

While DOJ’s FCPA guidance may explain part of the diminished FCPA enforcement activity, another DOJ policy appears to have had a material impact on the disposition of FCPA cases, particularly for corporations under investigation. In June 2025, DOJ’s Criminal Division issued a revised Corporate Enforcement Policy (CEP) designed to streamline the charging calculus in cases involving companies. By and large, the CEP offered potential benefits to companies that:

• voluntarily self-disclosed misconduct;
• fully co-operated with DOJ’s investigation; and
• timely and appropriately remediated.

While prior iterations of the CEP created a presumption of a declination if a company satisfied these requirements, the revised version requires a declination.

DOJ is also likely to tap into a fertile source of information from the Whistleblower Program to fuel its surge of False Claims Act enforcement.

Greece

In Greece, in cases involving bribery of public officials, political figures or members of the judiciary, as well as trading in influence and related offences, a person may be granted whistle-blower (public interest witness) status, provided that they are not involved in the offence and do not seek any personal benefit. This status is granted by financial crime prosecutors, with the approval of the Head Prosecutor, where the individual provides information that significantly contributes to the detection and prosecution of the offence.

The law provides protective measures for such whistle-blowers, including confidentiality, and in some cases, immunity from prosecution, in order to encourage reporting without fear of retaliation.

Portugal

In Portugal, both general and sector-specific frameworks establish the existence of mandatory internal and external whistle-blowing channels, which must ensure confidentiality and anonymity. These regimes also provide for a strict prohibition of retaliation against whistle-blowers, accompanied by significant administrative sanctions in the event of breach. Furthermore, in many legal frameworks (eg, under Law No 93/2021, the Securities Code and anti-money laundering legislation), whistle-blowers benefit from immunity or exemption from liability where reports are made in good faith. In certain contexts, particularly under the Securities Code, there is also a presumption that any detrimental measures adopted following a report constitute retaliation.

As regards incentives, these are essentially of a negative or protective nature, consisting primarily in the prohibition of retaliation, immunity from liability, and procedural support mechanisms. Although, in areas such as auditing, European Union law allows member states to establish incentive schemes for internal whistle-blowers, there does not appear to be, under Portuguese law, a generalised regime providing for financial rewards or bonuses.

Anonymous reporting is expressly permitted. Mechanisms for anonymous reporting exist both internally within organisations – under Law No 93/2021, anti-money laundering frameworks, and regulatory notices issued by Bank of Portugal – and externally, through competent authorities such as the Portuguese Securities Market Commission, Bank of Portugal, and other sectoral regulators, in accordance with the applicable legal regimes.

Switzerland

Switzerland currently lacks comprehensive legislation protecting whistle-blowers in the private sector. Multiple legislative proposals have been rejected by Parliament, most recently in 2024 when the National Council again voted against a new whistle-blower proposal.

As a result, the measures whistle-blowers may take to report misconduct and the circumstances under which they may report externally have been established primarily through case law.

Under Articles 321a(1) and 321a(4) of the Code of Obligations (CO), employees owe a duty of loyalty and confidentiality to their employer, meaning they must generally report misconduct internally first. Only if internal reporting is exhausted and a public interest concern exists may an employee escalate to authorities, and disclosure to the media is permitted only as a last resort. Whistle-blowers who breach these obligations risk criminal prosecution – for example, under Articles 162 SCC (business secrecy) or 47 of the Banking Act (banking secrecy) as well as dismissal. While termination solely for lodging a complaint may constitute unfair dismissal, the remedy is limited to compensation of up to six months’ salary, with no right of reinstatement.

Switzerland offers no financial incentives for whistle-blowers comparable to programmes in the United States. However, anonymous reporting mechanisms do exist.

In 2015, the Swiss Federal Audit Office launched an anonymous electronic reporting platform allowing the public to report suspicions of corruption, or fraud with guaranteed anonymity.

Private entities are not legally required to establish whistle-blowing systems, though doing so is considered best practice and may be implicitly expected under corporate governance obligations. The OECD has repeatedly urged Switzerland to adopt stronger protections for private-sector whistle-blowers.

Singapore

In Singapore, protection for whistle-blowers is provided through a combination of statutory provisions and regulatory guidance.

Under Section 36 of the Prevention of Corruption Act, complaints made to the authorities cannot be admitted as evidence in civil or criminal proceedings, and no witness is required or permitted to disclose the identity of an informer.

The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act also imposes reporting obligations on persons who know or suspect that property is linked to criminal conduct. Good faith disclosures to a Suspicious Transaction Reporting Office (STRO) are protected from civil or criminal liability and do not constitute a breach of confidentiality obligations.

In addition, the Code of Corporate Governance encourages listed companies to implement whistle-blowing policies that allow employees to report concerns confidentially.

While there is no general statutory guarantee of anonymity, reporting channels (including submissions to an STRO and reports to the Corrupt Practices Investigation Bureau) are structured to protect the identity of informants in practice.

Enforcing anti-money laundering laws

The global need to prevent and detect money laundering is paramount. Financial criminals and fraudsters need to launder the proceeds of their crime.

The UK has made this a top priority. In response to the threat of money laundering, ECCTA includes provisions relating to Companies House reform aimed at improving corporate transparency, as well as measures concerning the seizure and recovery of crypto-assets, intelligence sharing, and proactive intelligence gathering by law enforcement agencies. Last year the government produced its proposals for improving the effectiveness of the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs).

Other nations have all adopted a similar approach.

In April 2024, the EU, in an effort to combat money laundering and terrorist financing provided Financial Intelligence Units (FIUs) with more powers to analyse and detect money laundering and suspend suspicious transactions. This includes enhanced due diligence measures and checks on customers’ identities. In addition, the Authority for Anti-Money Laundering and Countering the Financing of Terrorism has been created to ensure that EU anti-money laundering rules are applied correctly and consistently.

In conclusion

Financial crime is a global epidemic. It has been and remains a threat to the integrity of the world’s corporate and financial system. The year-on-year growth rate of the losses associated is colossal. The illicit proceeds are globally laundered to fund further crimes including terrorist financing and human trafficking.

Financial crime is industrialised and global. Criminals are innovative, adopting and enhancing the effectiveness of their fraudulent schemes via technological advances such as AI to exploit the financial system for their own gain and at a pace at which funds have disappeared through faster digitalised payment channels and moved across borders even before detection.

These technological advances have reshaped the global financial crime landscape, making financial crime more difficult to combat and more lucrative for the criminal enterprises.

It seems that the global consensus to combat financial crime is to:

• continue to develop legal frameworks and to try to harmonise with other jurisdictions;
• expand enforcement and make international co-operation and collaboration with law enforcement agencies easier;
• have mechanisms in place such as DPAs and whistle-blowing provisions with incentives to encourage disclosure of corporate wrongdoing;
• make compliance and governance including risk assessment mandatory for corporate, legal and financial institutions to prevent or make it difficult for the criminal enterprises to exploit the financial system;
• provide law enforcement agencies globally with the tools and resources to investigate and to detect financial crimes as early as possible to mitigate losses and to also be able to recover the proceeds of crime and use sanctions when necessary;
• invest in and utilise technological advances and AI to prevent, detect and mitigate financial crime.

This final point, however, presents both opportunities and challenges. While AI promises faster detection and improved risk assessment, it is of concern to all to ensure that its use remains explainable, unbiased and supported by adequate human oversight.

The 2026 edition of the Chambers Financial Crime Global Practice Guide has been written to ensure that practitioners are equipped to manage all aspects of financial crime in the jurisdictions in which they operate and are able to advise their clients accordingly.

The Chambers Global Financial Crime Guide provides both assistance and insight to those who operate in the corporate sector. It is an informative resource that focuses on and explains the key issues that are faced at all stages of an investigation.