Panoramic: Automotive and Mobility 2025
Insights and Analysis
Global Bribery, Investigations and Enforcement Outlook 2026
13 January 2026
Key takeaways
Fully implemented and evolving compliance programs are non-negotiable: Programs must account for applicable anti-bribery, trade, data privacy, fraud, and other risks.
Carrots for cooperation: Regulators seek to use DPAs and declinations as incentives for self-disclosure and cooperation.
Expanding liability and personal exposure: New strict liability offenses, senior manager attribution, and focus on individual accountability raise the stakes globally.
AI and investigations: As AI delivers opportunities for compliance and investigations, it also creates novel challenges – and regulators are taking notice.
Third-party and supply-chain scrutiny intensifies: ESG and anti-corruption risks converge, heightening the importance of robust compliance as enforcement targets high-risk sectors and subcontracting chains.
The enforcement risks facing multinationals – and, by extension, their legal and compliance leaders – are multiplying. In recent years, anti-bribery concerns have been joined by a host of other risks – from sanctions and export controls to ESG and data privacy – with enforcement activity expanding. Consistent with these trends, this publication is itself evolving, from the Global Bribery and Corruption Outlook of years past to this new Global Bribery, Investigations, and Enforcement Outlook for 2026 – retaining a focus on anti-bribery risks, while broadening our lens to more fully capture other growing risks. Along these same lines, we anticipate 2026 to be a year in which emerging enforcement patterns yield concrete results, with aspects ranging from refocused Foreign Corrupt Practices Act (FCPA) enforcement to increasingly robust enforcement in Asia coming into clearer focus.
Global Bribery, Investigations and Enforcement Outlook 2026.
From a U.S. perspective, the key events of 2025 were the Trump Administration's pausing of enforcement under the FCPA and the subsequent resumption of enforcement – under new Department of Justice (DOJ) FCPA enforcement guidelines focusing on cases that are tied to drug cartels and transnational organized crime and that otherwise implicate U.S. competitiveness and national security. Companies must monitor U.S. enforcement developments and account for the evolving incentives – favoring voluntary self-disclosure and cooperation – that DOJ continues to emphasize. In the Western Hemisphere more generally, Latin America remains a challenging region for anti-corruption compliance and a focus of U.S. enforcement, including under DOJ's revised guidelines.
Across the Atlantic, the United Kingdom enters 2026 with a more active corporate enforcement environment, led by the Serious Fraud Office pursuing faster investigations, a presumption of deferred prosecution agreements for self-reporting companies, and a prevention-led partnership with business. Other agencies are expanding activity, while the new Failure to Prevent Fraud offense raises expectations on controls. International dynamics are shifting too – if the momentum holds, 2026 will test whether these changes amount to lasting improvement and a more prominent global role for the United Kingdom.
Meanwhile, the Asia-Pacific region's anti-corruption landscape is undergoing a raid transformation, with regulators deploying bold new tactics, record fines, and unprecedented penalties. The gloves are off: cross-border collaboration is intensifying, and executives are now facing real risks of personal accountability. Compliance complacency is no longer an option – proactive, robust controls are essential to stay ahead of the next enforcement wave.
This Outlook also examines a number of topics that cut across regions. Preserving legal privilege is often a key concern in internal investigations, and recent U.S. and EU case law alike underscores the need to meet applicable requirements for legal privilege protection arising from counsel's advice and work product. As privilege standards around the world continue to evolve, it has become increasingly important for companies to take a thoughtful approach to privilege when structuring and conducting internal investigations – particularly those that cross borders.
Artificial intelligence (AI) presents both challenges and opportunities to compliance and investigations. While AI introduces new risks that demand careful management, it also offers significant opportunities to enhance the efficiency, accuracy, and depth of compliance monitoring and investigative processes. Meanwhile, governments in various jurisdictions are establishing expectations for the use of AI in the compliance setting and are themselves deploying AI tools to detect misconduct, potentially increasing enforcement risks.
Another example of evolving compliance challenges relates to how companies are strengthening compliance and resilience by integrating anti-bribery measures with supply chain due diligence. As new EU directives and national laws reshape that landscape, a unified approach to governance, anti-corruption, and ESG risks is becoming essential for mitigating business partner risks and staying ahead of evolving enforcement trends.
This year, we're also spotlighting enforcement risks in the life sciences – a sector in which companies frequently find themselves under regulatory scrutiny. Shifts in U.S. law and policy, a new UK fraud offense, and China's introduction of anti-corruption and anti-monopoly guidelines for pharmaceutical and medical device companies will all impact the healthcare industry in the coming year.
Ultimately, given the growing range of compliance risks and emerging activity from new and dormant enforcement authorities, multinationals have little choice but to ensure their compliance programs are keeping apace with evolving risks and to carefully monitor enforcement trends.
Please read the Outlook here: Global Bribery, Investigations and Enforcement Outlook 2026
Authored by Calvin Ding and Matthew Sullivan.
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