Global investigations shift into high gear in 2026, according to Hogan Lovells

"Companies that integrate bribery, trade, data privacy, fraud, and related risks into one program are better equipped to move fast, fix issues, and remain resilient," said Stephanie Yonekura, Global Head of Investigations, White Collar and Fraud. "In 2026, the enforcement 'carrots' are real — but so are the expectations around how quickly and credibly companies can self‑disclose and remediate."

"Joined‑up enforcement and faster timelines are raising the bar on senior‑manager accountability in the UK and beyond," said Liam Naidoo, Deputy Head of Investigations, White Collar and Fraud. "Corporates need crisp governance on decision‑making and documentation, and must be prepared to explain their program choices to regulators."

Global trends to watch in 2026

• Integrated, cross‑risk programs becoming the baseline, with organizations unifying policy, training, monitoring and controls across bribery, trade, data privacy, and fraud.
• Cooperation 'carrots' are becoming even more meaningful for companies that move quickly, self-disclose early, and deliver documented remediation through disciplined investigations, with benefits including potential declinations and DPAs.
• Rising personal exposure as regulators focus on who made key decisions, how these decisions were documented, and whether boards and executives exercised effective oversight.
• Deeper scrutiny of third-party and supply chain risk, with ESG and anti-corruption diligence extending beyond tier-one suppliers.
• AI reshaping investigations and compliance, enabling faster detection and review while raising expectations around governance, including defensible use of technology; clear decision-making between legal, compliance and IT teams; robust audit trails; and careful handling of evidence and privilege in cross-border matters.

Enforcement around the world

• United States / FCPA. Cooperation 'carrots' remain meaningful for timely self‑disclosure and credible remediation; be ready to move early with disciplined investigations and measurable fixes.
• United Kingdom. A joined‑up enforcement landscape and faster timelines heighten senior‑manager accountability; crisp governance and contemporaneous documentation are vital.
• Asia‑Pacific. Expect assertive multi‑agency action and closer attention to cross‑border data and privilege in coordinated investigations.
• Latin America. Public procurement and large infrastructure projects remain high‑risk; third‑party governance is the dominant exposure point. Tighten tender controls, strengthen onboarding/monitoring of distributors and agents, and reinforce whistleblowing channels.
• Sector lens: Life sciences. Heightened scrutiny across supply chains, data use, and interactions with public officials calls for sector‑specific training and controls.

Practical guidance: what companies should do now

Editors of the Outlook emphasize that companies need to operationalize these actions differently across jurisdictions.

“In the U.S., companies should be prepared for an environment of refocused FCPA enforcement—consistent with new DOJ guidelines—while remaining cognizant of a host of other growing risks, ranging from sanctions and export controls enforcement to False Claims Act investigations and litigation,” said Matt Sullivan, partner and co-editor of the Outlook based in New York. “That requires triaging and responding to compliance issues and whistleblower reports promptly, keeping compliance tools including use of AI on pace with the growth of business activities, conducting effective third-party diligence, and implementing documented remediation with issues are identified. Organizations that move swiftly and can show tangible fixes are far better positioned to secure favorable resolutions of government investigations.”

“Outside the Americas, companies should be strengthening cross-border investigation readiness before issues arise,” said Calvin Ding, partner and co-editor of the Outlook based in Shanghai. “This includes deepening third-party oversight across complex supply chains, pressure-testing data transfer and privilege strategies, and putting in place investigation and disclosure processes that can withstand parallel inquiries and regulator scrutiny across multiple jurisdictions.”