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).