Corporate Crime & Investigations: Global trends and enforcement risks for 2026

The corporate crime and investigations landscape evolved at pace in 2025. Financial sanctions and export controls continue to drive risk in the UK, Asia, and Australia. AML frameworks across EU Member States and in the Middle East have undergone significant reform, raising the compliance bar for businesses operating in those regions.

Looking ahead to 2026, we predict that bribery and corruption, tax evasion, and fraud will be enforcement priorities for authorities globally. We also anticipate the debate regarding the protection of whistleblowers – and calls to introduce financial reward programmes – will continue. Finally, we expect the day-to-day conduct of investigations to become increasingly tech-enabled as internal and external investigations teams seek to harness artificial intelligence tools to speed-up the investigations process.

As we enter the new year, experts across our Global Investigations practice have identified the risks and trends they expect to be a priority for in-house legal and compliance teams in their region in 2026.

Asia

Singapore cracks down on scams – will crypto be next?

With victims in Singapore having lost close to SGD 4 billion (approx. USD 3.1 billion) from scams between 2020 and 2025, Singapore has taken decisive legislative steps to strengthen its anti-scam arsenal, targeting every stage of the scam lifecycle:

• Prevention: The Protection from Scams Act 2025, which took effect on 1 July 2025, introduced measures to protect potential scam targets. Police are empowered to issue restriction orders (RO) to banks, to restrict banking and credit facilities where there is a reasonable belief that an individual may transfer, withdraw, or draw down funds to benefit a scammer.
• Regulation of online platforms: Taking a more interventionist stance, the first implementation directive under the Online Criminal Harms Act 2023 was issued to a social media platform in September 2025, requiring it to put in place measures to target scams impersonating key Government office holders on its platform or face fines of up to SGD 1 million (approx. USD 800,000). Similar directives were subsequently issued in November 2025, reinforcing Singapore's commitment to holding online platforms accountable for scam-related content.
• Infrastructure disruption: The Facility Restriction Framework which was rolled out in October 2025, enables restrictions to be imposed on scam mules. The measures restrict their access to banking services and new mobile lines, disrupting their provision of key infrastructure that enables syndicate operations to thrive. There are plans to extend these restrictions to Government digital authorisation systems such as Corppass and Singpass, which scammers often exploit to access higher-risk platforms and services.
• Deterrence: In a further move to strengthen deterrence, Singapore passed the Criminal Law (Miscellaneous Amendments) Bill on 4 November 2025, which legislated mandatory caning of at least 6 strokes (up to 24 strokes) for scammers and members or recruiters of scam syndicates. Scam mules may also face discretionary caning of up to 12 strokes.

Looking ahead to 2026, we expect the focus to be on stricter enforcement and utilisation of the various legislative levers to combat scams. Given the robust legislative framework, scammers are likely to turn to cryptocurrency to evade traditional banking safeguards, prompting increased legislative and regulatory intervention in the cryptocurrency industry. This is likely to include possible expansion of ROs to cryptocurrency exchanges.

Clarence Ding

Hong Kong’s focus on IPO‑related regulatory concerns and misconduct

In 2025, Hong Kong’s initial public offering (IPO) market saw a significant resurgence, reclaiming the top spot in global IPO market rankings for the first time since 2019. With some 300 active IPO applications in the pipeline as of December 2025, Hong Kong’s strong IPO momentum will carry well into 2026.

The significant rebound of the Hong Kong IPO market in 2025 has given rise to practical challenges for IPO practitioners, not least in ensuring adequate resources and manpower with sufficient experience.

In Hong Kong, IPO sponsors and individual sponsor principals serve a critical gatekeeping function that underpins market integrity and investor confidence in the equity capital market. The Securities and Futures Commission (SFC) and the Stock Exchange of Hong Kong (HKEx) expect them to perform listing due diligence with sufficient professional scepticism.

Notably, it was reported in December 2025 that the SFC and HKEx jointly wrote to investment bank IPO sponsors to express their regulatory concerns over declining quality and substandard behaviour in certain listing applications, and to remind sponsors of the regulatory consequences for breaches. This is a key area of regulatory risk and focus in 2026.

IPO‑related misconduct and failures have been the focus of the SFC and the HKEx. Past SFC enforcement actions against IPO sponsors and their principals have covered a range of issues, including failures to conduct reasonable due diligence, inadequate testing of business models, and undue reliance on listing applicants’ representations. Past sanctions include record‑breaking fines of up to HK$375 million, and suspension or revocation of licences for licensed corporations and individual sponsor principals.

We continue to see the HKEx and SFC collaborating closely on investigations and enforcement actions against IPO‑related misconduct, including misuse of IPO proceeds, non‑disclosure of the expected use of IPO proceeds in listing prospectuses, and IPO sponsor failures. We expect their close collaboration on this key risk area to continue in 2026 under the SFC’s new Head of Enforcement, Mr Michael Duignan, who was the SFC’s Head of Corporate Finance overseeing listing market regulation and market integrity.

Cliff Chow

Expansion of outbound investment regulations and tightening of export controls

Since its entry into force on 2 January 2025, the US Outbound Investment and Security Program (OISP) has had a significant impact on US investments into China, Hong Kong and Macau. The regime is poised for further expansion in 2026. President Trump's America First Trade Policy (AFIP) has ordered the US Treasury to reassess whether the OISP has “sufficient controls,” and AFIP agencies to consider adding biotechnology, hypersonics, aerospace, advanced manufacturing, directed energy, and other Military‑Civil Fusion areas to the program’s scope. It also contemplates tightening coverage of private equity, venture capital, greenfield projects, corporate expansions, and publicly traded securities.

In Congress, the bipartisan Foreign Investment Guardrails to Help Thwart (FIGHT) China Act, if and when passed, would codify the OISP and broaden prohibitions to include high‑performance computing/supercomputing and additional activities in existing sectors, shorten the notification deadline to 14 days, and narrow current exceptions - moving toward a clearer “red light/green light” regime. Treasury has meanwhile sharpened implementation through rolling FAQs and an enforcement framework with proactive outreach, signalling readiness to administer a broader program. Leadership focus is also increasing, with the Assistant Secretary for Investment Security overseeing both OISP and the CFIUS. Taken together, these steps indicate likely near‑term expansion in both sectoral coverage and transaction types, along with faster timelines and fewer exceptions.

From an export controls perspective, 2026 is likely to see the US continue to tighten export restrictions on advanced technologies and critical minerals to China. Sophisticated controls to further slow Chinese efforts to develop semi-conductor, AI and other technologies are likely to develop including via designations on the Commerce Department's Bureau of Industry and Security Entity List, and through additions via the Foreign Direct Product Rule.

Alexander Dmitrenko

Australia

Australia's Tranche 2 AML/CTF reforms come into effect

Long-awaited changes to Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime will take effect in 2026.

For reporting entities already regulated under that regime, such as financial institutions, and now virtual asset and value transfer services, key changes include substantial amendments to the obligations to perform ML/TF risk assessments, which (among other things) must be tailored to the entity, having regard to the nature, size and complexity of the entity's business, and continually reviewed and kept up to date. The risk assessments must flow through to AML/CTF policies and procedures. There are enhanced governance requirements: governing bodies must have strategic oversight of ML/TF risk and AML/CTF compliance officers have additional obligations. These reforms come into effect from March 2026 and will ensure that Australia is brought into alignment with the international Financial Action Task Force standards.

The other significant changes involve the application of the AML/CTF regime to additional businesses, including lawyers, accountants, trust and company service providers, real estate professionals, and dealers in precious metals and stones ('Tranche 2 entities'). These newly regulated entities will have to enrol with AUSTRAC, the regulator for AML/CTF, and comply with all standard AML/CTF obligations, such as developing and maintaining an AML/CTF compliance program tailored to their business; undertaking risk-based customer due diligence; conducting ongoing monitoring; and submitting suspicious matter and threshold transaction reports. These obligations commence from 1 July 2026.

AUSTRAC has released 'core guidance', clarifying how it will interpret the amended AML/CTF Act and new rules, and what it expects reporting entities to do to meet their obligations; further sector-specific guidance is expected shortly.

The upshot: 2026 will be a busy year both for AUSTRAC and for regulated entities, as existing reporting entities embed changes to policies and procedures to comply with the reforms, and as 'Tranche 2 entities' work through all the steps needed to meet their new AML/CTF obligations.

Rani John, Kirsten Scott and Felicity Healy

Expect continuing activity in shaping and enforcing Australia's autonomous sanctions regime

In 2025, two separate Parliamentary Committees reported on Australia’s autonomous sanctions regime: the Senate Foreign Affairs, Defence and Trade References Committee (February 2025) and the Joint Standing Committee on Foreign Affairs, Defence and Trade (March 2025). The recommendations of both Committees pointed to a need for sharpened focus on enforcement, including coordinated action with partners, continued designations for serious human rights abuses, and the development of methodologies to assess the effectiveness of Australia’s regime.

Complementing those reports, the Government has said it intends to make the sanctions regime clearer and more workable, to reduce unnecessary or duplicated regulatory costs and work with international partners to identify opportunities to improve regulation. Against this backdrop, 2026 is likely to be a year of policy design to inform eventual legislative reform.

The Australian Sanctions Office, the regulator for Australian sanctions regimes, issued new guidance in 2025 to assist businesses with compliance. That guidance, together with budgetary commitments to support sanctions enforcement and the Australian Federal Police's announcement in October 2025 that they have charged a man for suspected contraventions of sanctions laws, suggests continued momentum towards more visible enforcement and a maturing compliance expectation for Australian corporations.

Pending relevant reforms, the pressure points remain familiar. Persistent ambiguity in Australia's autonomous sanctions framework – particularly the absence of bright line rules for assessing whether an entity is owned or controlled by a designated person (as we discussed here) – will continue to complicate risk assessments. We expect continuing civil litigation around interpretation and application of Australia's sanctions regime.

Rani John, James Clarke and Felicity Healy

Europe

An increased focus on tax enforcement in France

Tax investigations and enforcement action in France are set to intensify significantly in 2026, driven by a combination of record-level audit recoveries, advanced analytical tools, and significant increases in enforcement resources. Three specific trends stand out:

• French tax authorities are operating at historic levels, with €11.4 billion recovered in 2024, the highest since 2019. This rebound has been driven by increasingly sophisticated tools and a political priority to accelerate the fight against fraud and illicit financial flows. However, authorities also recognise that billions in assessed tax remain uncollected, creating further pressure on enforcement teams to secure effective recovery, a trend that businesses will feel more directly in 2026.
• Data-driven audits are rapidly reshaping tax enforcement. More than half of professional audits now originate from AI-assisted data mining, a dramatic rise from 22% in 2019. This shift means authorities can detect complex, cross-border or structurally concealed schemes more efficiently, creating a higher risk of targeted investigations for corporate groups and financial institutions.
• France's 2023-2027 anti-fraud plan (plan fraude) is materially strengthening the State's investigative capacity. More than 780 fraud-fighting positions have been created or opened since 2023, including a doubling of judicial tax officers (officiers fiscaux judiciaires), the establishment of the new Fiscal Intelligence Unit (Unité de Renseignement Fiscal), and significant reinforcements to transfer-pricing, international transparency, and recovery teams. Tracfin – France's financial intelligence unit – has seen suspicious-activity reports nearly double since 2020 and is scaling up its data analytics and investigative tools.

Recent raids on major French banks underscore these trends. In June 2025, offices of a global financial institution in Paris and Luxembourg were searched as part of a large-scale preliminary investigation into alleged "aggravated tax fraud", "laundering of tax fraud" and "criminal conspiracy". Several senior employees were placed in custody, and the investigation is examining whether tax-optimisation structures offered to corporate clients – including via Luxembourg subsidiaries – amounted to facilitation of tax fraud. This mirrors a broader enforcement shift: authorities are increasingly targeting intermediaries, financial institutions and facilitators, not only taxpayers.

Alexis Werl

AML compliance to remain a priority in Germany

AML enforcement risk is likely to remain elevated in Germany and across Europe in 2026, with supervision becoming more assertive and targeted. This is reflected in the objectives set by Germany’s financial regulator, BaFin, for 2026 to 2029. These include increased inspections with faster follow-up where weaknesses are identified, greater use of data-driven supervision, and a particular focus on payment transactions and the crypto market.

The trend towards stricter oversight was already evident in 2025, with two notable examples. First, BaFin imposed a record €45 million fine on a global financial institution for failing to promptly file suspicious transaction reports, highlighting the consequences of deficiencies in reporting frameworks and escalation processes. Second, the “Operation Chargeback” investigation, concerning fraud and money laundering schemes targeting German payment service providers, demonstrated the ability of German authorities to coordinate cross-border operations, including searches, arrests, and asset measures exceeding €35 million.

In this environment, maintaining a reliable, risk-based AML framework is crucial. As Birgit Rodolphe, Chief Executive Director of Resolution and Prevention of Money Laundering recently emphasised, risk is the organising principle of effective prevention. BaFin expects ongoing exposure assessments, with preventive measures calibrated accordingly and grounded in a clear understanding of customers, business models, and transaction patterns.

EU-level developments will add further momentum: the new Anti-Money Laundering Authority will expand its operational work in 2026, and the EU Anti-Money Laundering Regulation is set to apply from 2027.

The priority for in-house legal and compliance teams in 2026 will be to closely monitor regulatory developments and continuously refine their AML frameworks to withstand intensified supervision.

Volker Rosengarten

Middle East

AML will continue to be a key focus

Building on the developments over the last 12 months, we expect to see a continued focus on the UAE's financial crime framework, particularly in respect of AML. This follows the UAE's removal from both the FATF grey list in early 2024 and the EU's list of high-risk countries in mid-2025, and the sustained efforts following these developments to reform the UAE's financial crime reputation.

In 2024, the UAE released the 2024-2027 National Strategy for Anti-Money Laundering, Countering the Financing of Terrorism and Proliferation Financing (the Strategy), which set out 11 strategic goals and specific legislative actions and regulatory reforms required to support the Emirates' progression towards global best practice. The UAE is now also preparing for the fifth round of FATF mutual evaluation in 2026. Against this backdrop, the UAE recently introduced a new AML and Counter terrorism Financing Law (Federal Law No. 10 of 2025) (the New AML Law).

The New AML Law came into effect on 14 October 2025 and marks a significant regulatory development. It sets out enhanced and more robust enforcement measures, broadens the scope of offences, and aligns evidentiary standards with those of other jurisdictions. Key changes include:

• Broader scope for virtual assets and proliferation financing. Virtual asset activities and certain fintech business models now fall squarely within the New AML Law. The law has expanded in scope to recognise offences committed through digital systems and encryption and codifies proliferation‑financing controls.
• Greater investigative and enforcement powers given to the Financial Intelligence Unit. The FIU may now suspend suspicious transactions for up to 10 working days and freeze funds for up to 30 days (which is extendable). The regulators have also been given broader investigative and information‑gathering tools.
• Lower evidentiary thresholds. Circumstantial evidence and inferred knowledge may now suffice to prove certain offences, so actual knowledge is no longer required. This aligns the UAE's standards more closely with international best practice, including the UK. We fully expect this will increase the number of prosecutions.
• New oversight architecture. A Supreme Committee will now oversee national AML/CFT strategy and supervise the existing National Committee. This rearrangement has been introduced to enhance regulatory coordination and effectiveness but also shows that AML and CTF is being given priority status by the Government.
• Tougher penalties and personal liability. The New AML Law introduces (i) mandatory prison sentences (typically one to ten years) for specified offences; (ii) higher fines (up to AED 10 million, with no statutory upper limit for some offences); and (iii) direct liability for legal entities and responsible managers/ office holders.
• Strengthened international cooperation and asset recovery. Significantly, the New AML Law provides that foreign confiscation judgments and orders can be recognised and enforced in the UAE even without a domestic investigation or reciprocity agreement in place. This should simplify cross‑border recovery of criminal proceeds and address public perception issues.
• No limitation periods. Criminal, civil, and administrative actions tied to money laundering, terrorism financing, and proliferation financing are no longer subject to a limitation period.

In addition to legislative change, there has been a clear trend of enhanced regulatory scrutiny and action in the UAE. In onshore UAE, we have seen the Central Bank (CBUAE) issue higher penalties and licence interventions across financial institutions and other high-risk industries, such as precious metals. Notably, in the last 12 months the CBUAE has issued substantial fines to and/or suspended the licences of foreign exchange houses and at least one branch of an undisclosed foreign bank for failures relating to AML systems and controls. The CBUAE fines in 2025 have ranged from AED 3.5 to AED 200 million.

The regulators in the financial free zones have also increased their respective enforcement activities over the last year – a trend we expect to continue. The DIFC regulator, the Dubai Financial Services Authority (DFSA), has continued to issue sanctions relating to market-abuse, reporting obligations, and AML systems and controls failures, which is a key focus area for the DFSA. Dubai's Virtual Assets Regulatory Authority has also intensified its unlicensed activity-sweeps, issuing cease‑and‑desist orders, fines, and public warnings to multiple crypto operators in 2025. Down the road in the ADGM, the Financial Services Regulatory Authority or FSRA has also ramped up enforcement activity. Recently the FSRA issued a USD 500,000 fine against a brokerage firm for long‑running and very serious AML control failures.

Emma Tormey

UK

UK AML: enforcement gathers pace - and reforms to the MLRs are coming

The FCA's 2025 enforcement record against firms confirms that anti-money laundering remains a top supervisory priority. The FCA imposed fines totalling approximately £76m for financial crime breaches, including failures to identify, assess, monitor and manage adequately money laundering risks. The message is clear: the regulator expects clearly articulated, risk-based AML systems and controls to operate effectively at onboarding and throughout the customer lifecycle, with demonstrable risk assessment, ongoing monitoring and prompt escalation. Firms should expect continued scrutiny of high-risk relationships and legacy processes, and ensure they can evidence how AML risks are effectively identified, managed and overseen in practice.

Targeted reforms to the UK Money Laundering Regulations (MLRs) proposed by HM Treasury, expected to take effect in 2026, will impact the level of customer due diligence (CDD) firms need to conduct. The reforms aim to close regulatory gaps, clarify CDD requirements and give firms more scope to apply a risk-based approach. Overall, HM Treasury has signalled the introduction of a more proportionate, targeted approach to tackling money laundering. For example, the list of high-risk third countries triggering an obligation for firms to conduct enhanced due diligence (EDD) will be limited to those on the Financial Action Task Force 'black list' and no longer includes those on the 'grey list'. The revised MLRs will also clarify that EDD is only mandatory for "unusually complex or unusually large" transactions, rather than "complex or unusually large" transactions.

Andris Ivanovs

UK strengthens incentives to report on tax avoidance and evasion

As part of the Autumn Budget, HMRC launched a Strengthened Reward Scheme, coming into force with immediate effect, to incentivise whistleblowers to report serious tax avoidance and evasion, underscoring the government's shift toward leveraging insider intelligence in an effort to close the UK’s tax gap (c. £45 billion in 2023/24).

The scheme offers discretionary awards of 15–30% of tax recovered where tips result to the collection of at least £1.5 million in tax. The scheme is designed to encourage disclosures and intelligence and increase investigative activity into tax evasion and avoidance. While modelled on the US IRS program, there are notable differences. Under the HMRC scheme awards remain wholly discretionary; complicit insiders are excluded from eligibility; guidance on confidentiality and timelines is sparse; and, unlike the established IRS Whistleblower Office, HMRC does not have a dedicated office to administer the reward scheme. These differences may affect the scheme's success.

Nevertheless, HMRC’s strengthened scheme could result in an increase in whistleblower disclosures and associated investigatory activity. Tax compliance has been an area of heightened scrutiny for some time and this new scheme suggests that firms are likely to continue to face increased scrutiny in this area. Firms should ensure that they have in place robust internal whistleblowing channels, tax compliance and record-keeping procedures, and associated guidance for employees and stakeholders.

Judith Seddon

UK sanctions: expect more enforcement—and potentially more turbulence

In October 2025, the Office of Financial Sanctions Implementation (OFSI) published its annual review 2024 - 25. The review states that more than £37 billion of assets were reported to OFSI as frozen, including £28.7 billion attributable to UK sanctions against Russia. As at April 2025, OFSI was handling 240 active cases, with a growing proportion originating from non‑self‑reported sources (151 in 2024 - 25, up from 108 in 2023 - 24).

OFSI delivered six public enforcement actions in 2025. These included penalties for breaching financial sanctions against Russia, as well as for failing to comply with an information request from OFSI within the required timeframe. OFSI also publicly disclosed a bank's sanctions breach caused by an eight‑day delay in freezing assets following designation of a person under the UK's counter-terrorism sanctions regime. Alongside its enforcement activity, OFSI published a set of sector‑specific threat assessment reports, covering legal services, high‑value dealers and art market participants, property and crypto‑assets.

Policy change is also on the horizon. The government's response to its consultation on sanctions enforcement, expected to be published in early 2026, will likely include proposals for higher statutory maximum penalties, as well as the introduction of settlement and early account schemes (broadly modelled on those already run by the PRA).

Finally, firms should continue to expect changing geopolitics to shape sanctions risk. With peace negotiations concerning Russia's invasion of Ukraine on the horizon, UK, EU and US sanctions against Russia will be a potential bargaining chip. Selective easing of sanctions may form part of an agreed settlement, but firms should not expect an immediate and wholesale repeal of sanctions against Russia. Rather, we expect that the easing of sanctions will be linked to milestones in any negotiated agreement.

Andris Ivanovs

Anti-bribery and corruption: UK embarks on ambitious new strategy

In December 2025, the UK Government launched its Anti-Corruption Strategy. The five-year plan resets the UK’s approach to tackling bribery and corruption following a year in which the SFO failed to achieve any notable enforcement outcomes. The timing of the new strategy is also significant given the UK received its lowest-ever score (ranked 20th globally) in Transparency International’s 2024 Corruption Perceptions Index.

The strategy emphasises the harm caused by corruption to economic and national security interests and aligns efforts to tackle corruption with the Government’s wider growth agenda. It is an extensive, ambitious strategy supported by 123 commitments and based on three core pillars:

1. Targeting corrupt actors and their funds in the UK and overseas. The strategy aims to strengthen capabilities to investigate corrupt actors by expanding the new Domestic Corruption Unit in the City of London Police and leveraging the power of artificial intelligence to accelerate SFO investigations. There is a commitment to explore the funding landscape and explore opportunities to reform the UK’s approach to whistleblowing.
2. Tackling vulnerabilities to corruption in the UK. The second pillar seeks to tackle perceived vulnerabilities to corruption across politics and government, the public sector (including procurement) and British business. The strategy proposes creating an Ethics and Integrity Commission, tightening political finance and lobbying rules, and harnessing measures in the Procurement Act 2023 to protect public money from high-risk suppliers.
3. Building global resilience to corruption. The UK has a strong track record in collaborating with international partners on anti-corruption initiatives and this will remain a strategic focus. The Government has made a commitment to host a UK Countering Illicit Finance Summit and expand the UK’s network of overseas-based illicit finance experts. This follows the launch of the International Anti-Corruption Prosecutorial Taskforce in March 2025 by the SFO, France’s PNF and Switzerland’s Office of the Attorney General with the aim of enhancing cooperation, information sharing and joint investigations.

Corporates should expect better resourced, tech-enabled investigative agencies operating within an integrated enforcement framework. The strategy will further embolden the SFO which launched its own five-year strategy in 2024 and, in May 2025, announced what is set to be its first contested trial involving a corporate for failing to prevent bribery. Against this backdrop, we expect the enforcement risk for bribery and corruption to increase in the coming year.

Neil Donovan

AI in investigations – a new frontier?

Corporates are conducting internal investigations more than ever before, due to increasing compliance and governance expectations from employees, shareholders and foreign JV partners, motivated by an ever-increasing backdrop of regulatory and legislative requirements. The rise of generative AI has therefore prompted questions about how AI can be used to improve, expedite and reduce the cost of investigations.

Corporates are already deploying large language models, a form of Generative AI, to assist investigations in several ways:

1. Assisting the set-up and scoping of an investigation by summarising internal policies (for example, to enable lawyers to advise on setting up a policy-compliant investigation), and by creating schedules to track timelines and evidence gathering.
2. Increasing the speed and efficiency of e-Discovery relevance reviews by prioritising documents most likely to be relevant to the eyes of reviewers. An LLM can code documents for issues or categories, enabling investigators to focus on the data likely to matter most.
3. Creating natural language queries to identify key events, custodians, topics, and build chronologies of events. Those chronologies can help interviewers get to key facts more quickly with witnesses and might speed up the preparation of disclosures to enforcement authorities.

Although there are already several use cases for generative AI, two practical concerns remain: confidentiality and accuracy. Will data remain secure if an LLM is applied to it and can the LLM accurately assess the credibility of the content, the reliability of the author, or the veracity of the source in relation to information scraped from public sources?

The headline is that AI can – and should – form part of an investigation, but cannot replace trained and experienced investigators, or legal advisers. Efficiencies can be made in investigations, from scoping and data review, through evidential analysis and reporting.

As we move into 2026, we expect lawyers and legal technologists to be working hand-in-hand on investigations, training models to provide reasons for identifying data as relevant (which can be interrogated and considered), developing workflows which strip administrative tasks from investigators, leaving them able to focus on the essential practice of finding facts, understanding risk and – ultimately – improving corporate compliance culture and performance.

Ruby Hamid

Thanks to Jacqueline Turner, Peter Fountotos, Ariane Kea, Victoria Varela, Vincent Kurz, Tom Stroud, Kandice Clarke, Vanessa Hung, Anthony Asindi, Vicki Tang, Eleanor Zhao, Asha Owen-Adams, Jonas Weissenmayer, Nadine Azmi and Kate Dyson for their assistance.