Discovering, developing, and distributing new medicines and technologies to improve human and animal health is a complex task requiring input and collaboration from scientists to salespeople. The unique complexity of the industry increases the risks for bribery and corruption. Its heavy reliance on third-party intermediaries, such as distributors and consultants, distinguishes it from certain other industries.
In addition, life sciences companies often operate in emerging markets where corruption risks are elevated. At the same time, in countries like the United States and the United Kingdom, the industry is heavily regulated, leading companies to engage extensively with government officials in areas such as regulatory approvals, clinical trials, and reimbursement by government payers.
On top of all this, the sector has historically relied on gifts and hospitality to build relationships with doctors and others involved in patient care, practices that have increasingly come under scrutiny. Taken together, these factors create a high-risk environment for misconduct related to bribery and fraud, which necessitates using robust compliance and prevention procedures.
The U.S. shift: from global to domestic enforcer
In the United States, 2025 saw dramatic shifts in bribery and corruption enforcement. A pause in enforcing the Foreign Corrupt Practices Act in February 2025 disrupted bribery investigations, leading to a measurable decline in activity and a narrowing of enforcement priorities. During the pause, the Department of Justice (DOJ) reportedly closed nearly half its foreign bribery investigations. When DOJ resumed enforcement activity in August 2025, it did so with a decreased emphasis on U.S. companies and more routine business practices – which in turn could de-emphasize at least some types of life sciences-focused investigations.
Between February and June 2025, DOJ released several memos signaling its intent to focus on organizations smuggling drugs, including fentanyl, across the border. As part of DOJ’s intent to eliminate transnational criminal organizations and cartels, it plans to expand money-laundering investigations to include organizations involved in laundering funds used to make illegal drugs or counterfeit pill-making devices. This shift has potential implications for pharmaceutical industry players that deal in pain medication or manufacturing equipment, particularly as it relates to potential increased government scrutiny of their supply chains.
Notably, a 12 May 2025 memo made clear that enforcement of the False Claims Act and Anti-Kickback Statute were ongoing priorities in DOJ’s efforts to combat waste, fraud, and abuse. Investigations initiated against companies alleged to have defrauded government health care programs, or related to high-value gifts to health care providers and other indications of corrupt practices in the life sciences sector, should be expected to continue in full force.
New UK fraud offense joins bribery and tax evasion offenses
While U.S. international bribery prosecutions may be in decline, particularly where cases lack a clear link to national strategic interests, the global financial crime landscape remains highly active. In the United Kingdom, the Economic Crime and Corporate Transparency Act 2023 has changed the face of corporate criminal liability. On 1 September 2025, a new strict liability offense came into force: Failure to Prevent Fraud. This offense, alongside the existing Failure to Prevent Bribery and Failure to Prevent Tax Evasion offenses, creates a formidable triad of corporate criminal liability and a combined compliance burden.
The legislation casts a deliberately wide net. Any fraudulent misconduct with a UK nexus can fall within its jurisdiction, meaning U.S. and other foreign multinationals with UK touchpoints can squarely be exposed. The failure to prevent model in the United Kingdom requires organizations to implement reasonable procedures – or “adequate” procedures in the case of bribery – to successfully defend an allegation of failure to prevent misconduct. Procedures include undertaking integrated risk assessments and having in place proportionate procedures, including tailored training and robust monitoring mechanisms.
An effective compliance regime is, of course, more nuanced than gold-standard processes; successful organizations embed compliance within their culture, not just their procedures. The UK Serious Fraud Office (SFO) has further emphasized that compliance programs must be proactive, risk-based, and sector specific. In practice, this means multinationals can’t afford to treat compliance as a box-ticking exercise. SFO director Nick Ephgrave has been clear about his appetite to use this new legislative power, noting that “[c]orporations must get their house in order or be ready to face investigation”.
Companies in the life sciences space should take heed. They must demonstrate genuine commitment to fraud prevention, ensuring safeguards are operationally effective and aligned with the unique risks of the sector.
China tightens controls
Meanwhile, in January 2025, China introduced its first industry-specific anti-corruption and anti-monopoly guidelines for pharmaceutical and medical device companies. The framework includes some types of conduct that the State Administration for Market Regulation has not previously addressed, such as companies conspiring to monopolize the pharmaceutical market and share resulting profits.
In October 2025, China also revised its Anti-Unfair Competition Law to expand liability, close enforcement gaps, and introduce extraterritorial application, further raising the compliance stakes for companies operating in or with China.
The rise of coordinated enforcement
Internationally, cooperation among enforcement authorities has intensified, reflecting the increasingly global nature of bribery and corruption risks. For example, in March 2025, the SFO, France’s Parquet National Financier, and Switzerland’s Office of the Attorney General established the International Anti-Corruption Prosecutorial Taskforce. This initiative represents a significant step in aligning enforcement strategies across jurisdictions and is designed to streamline cooperation on complex, multi-jurisdictional bribery cases, particularly those involving multinationals.
Globally, we expect enforcement actions to rise, with international cooperation becoming a focal point of anti-bribery and corruption efforts. Companies that fail to prepare for this evolving risk landscape may find themselves caught off guard by multi-jurisdictional probes and escalating compliance expectations.
The Taskforce’s mandate emphasizes sharing expertise, insight, and strategy to seize opportunities for operational collaboration to tackle international bribery and corruption. This development signals a risk for life sciences organizations that operate across borders: misconduct in one jurisdiction is increasingly likely to trigger coordinated scrutiny in others. So, compliance policies and procedures must be harmonized across jurisdictions, risk assessments must account for cross-border exposure, and monitoring mechanisms must be capable of detecting misconduct that could attract the attention of multiple regulators simultaneously.
What compliance leaders must do
Even as the anti-bribery enforcement landscape remains uncertain in the United States, scrutiny of pharmaceutical, medical device, and other life sciences companies remains high. Given that landscape, life sciences companies would be well advised to at least maintain, if not bolster, their compliance monitoring and reporting programs.
The UK government has significantly increased funding for the SFO to enhance proactive investigations, signaling a clear intent to intensify law enforcement scrutiny and enforcement activity in 2026. While 2025 saw the UK’s first corporation charged with the offense of failure to prevent the facilitation of tax evasion, prosecutors will now actively be seeking landmark cases for the failure to prevent fraud offense to establish precedent, gain momentum, and act as a deterrent.
Globally, we expect enforcement actions to rise, with international cooperation becoming a focal point of anti-bribery and corruption efforts. Companies that fail to prepare for this evolving risk landscape may find themselves caught off guard by multi-jurisdictional probes and escalating compliance expectations.
For the life sciences sector, compliance is not simply a regulatory requirement, but a strategic safeguard. Investment in compliance programs today – covering auditing, monitoring, employee training, and third-party due diligence – can save companies from the far greater costs of fines, debarment, reputational damage, and operational disruption tomorrow. In an industry where patient trust and public health are paramount, compliance is both a financial necessity and a moral imperative.