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A Chatham House Rule discussion with Michael Leo Gallagher, Chief Investigator, Serious Fraud Office, designed for senior in-house compliance leaders.
Date: Tuesday, 30 June 2026
Time: 10:30am – 12:30 pm, followed by lunch
Venue: The Bentley Hotel, London
The UK anti-corruption framework is entering a new phase. The Economic Crime and Corporate Transparency Act has expanded corporate liability, the failure to prevent fraud offence is now in force, and the first criminal prosecution under Section 7 of the UK Bribery Act has commenced. The SFO’s 2026–27 business plan signals a more targeted, intelligence-led approach to enforcement — and a clearer set of expectations for how compliance programmes are designed, evidenced, and improved over time.
This session brings a small group of senior in-house compliance leaders together with the SFO’s Chief Investigator for a discussion of what the new environment means in practice.
What we’ll discuss
- Current SFO enforcement priorities and the practical signals from the 2026–27 business plan
- How the SFO is approaching the failure to prevent fraud offence and the expanded senior manager attribution test
- What “reasonable” and “adequate” procedures look like in practice — and how programme effectiveness is being assessed
- Escalation, investigation, and the role of feedback loops in demonstrating a mature programme
- Third-party risk, cross-border cooperation, and the Five Eyes corruption indicators
Format
This session is intentionally small and discussion-led, with attendance limited to 15–20 senior in-house compliance leaders.
This is not a panel discussion or keynote presentation. The format is designed to encourage candid conversation between practitioners and the regulator under the Chatham House Rule.
About the speaker
Michael Leo Gallagher is Chief Investigator at the Serious Fraud Office.
Request an Invitation
Places are limited and available by invitation only. Attendance is reserved for senior in-house compliance, legal, and risk professionals.