Risk, Compliance & Financial Integrity across borders

Sources for the worked example

Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.

1. A commercial organisation commits an offence if a person associated with it bribes another person to obtain or retain business or a business advantage for it, unless it proves it had adequate procedures designed to prevent such conduct. Applies to UK-incorporated bodies and partnerships wherever they do business, and to any other body or partnership that carries on a business, or part of a business, in the UK.

   legislation.gov.uk (The National Archives) — Bribery Act 2010, section 7 · Section 7(1), (2) and (5) · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

2. The FCPA anti-bribery provisions make it unlawful to corruptly offer, pay, promise or authorise anything of value to a foreign official to obtain or retain business, and apply to all US persons and certain foreign issuers of securities and, since 1998, to foreign firms and persons who cause an act in furtherance of a corrupt payment within US territory. Federal. The Foreign Extortion Prevention Act of July 2024 separately makes it a crime for a foreign official to demand or accept such payments from issuers, domestic concerns and others, with up to 15 years' imprisonment.

   US Department of Justice, Criminal Division — Foreign Corrupt Practices Act · Overview of anti-bribery provisions and FEPA · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

3. The FCPA accounting provisions require companies whose securities are listed in the United States to keep books and records that accurately and fairly reflect their transactions and to maintain adequate internal accounting controls. Federal; applies to issuers. The Securities and Exchange Commission has civil enforcement authority under the FCPA.

   US Department of Justice, Criminal Division — Foreign Corrupt Practices Act · Accounting provisions · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

4. German bribery offences extend to bribery of foreign public officials, employees of international organisations and members of foreign and international courts. Applies §§ 331–334 StGB as specified in § 335a StGB.

   Bundesministerium der Justiz und für Verbraucherschutz / Bundesamt für Justiz (gesetze-im-internet.de) — § 335a StGB – Ausländische und internationale Bedienstete · § 335a(1) StGB · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

5. Germany has no corporate criminal liability as such, but a company can be fined up to EUR 10 million for an intentional criminal offence, and up to EUR 5 million for a negligent one, committed by its management in connection with the business. Administrative offence fines under § 30 OWiG; where a statute refers to § 30, the maximum for the relevant regulatory offence can be multiplied by ten.

   Bundesministerium der Justiz und für Verbraucherschutz / Bundesamt für Justiz (gesetze-im-internet.de) — § 30 OWiG – Geldbuße gegen juristische Personen und Personenvereinigungen · § 30(2) OWiG · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

   The § 30 page confirms the fine caps; the statement that Germany has no corporate criminal liability is general background and is not stated on that page.

6. The offence of failure to prevent fraud came into force on 1 September 2025: a large organisation is liable where an employee, agent, subsidiary or other person performing services for it commits a listed fraud offence intending to benefit it. Applies to bodies corporate and partnerships wherever incorporated. Not liable where the organisation was the intended victim. Fine, unlimited on indictment.

   legislation.gov.uk (The National Archives) — Economic Crime and Corporate Transparency Act 2023, section 199 · Section 199 and commencement note (SI 2025/349) · In force from 1 September 2025 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

7. An organisation is a large organisation for the failure to prevent fraud offence if, in the financial year before the fraud, it met two or more of: turnover above £36 million, balance sheet total above £18 million, and more than 250 employees. Separate rules in sections 201 and 202 apply to parent undertakings and groups.

   legislation.gov.uk (The National Archives) — Economic Crime and Corporate Transparency Act 2023, section 201 · Section 201(1) · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

8. A relevant body commits an offence under the Criminal Finances Act 2017 if a person associated with it criminally facilitates UK tax evasion, unless it proves it had reasonable prevention procedures or that it was not reasonable to expect any; the penalty is a fine. Section 45; applies whatever the size of the body. Unlimited fine on indictment.

   legislation.gov.uk (The National Archives) — Criminal Finances Act 2017, section 45 · Section 45(1), (2) and (8) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

9. Under the Department of Justice's department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy, the Department will decline to prosecute a company that voluntarily self-discloses, fully cooperates, remediates in a timely and appropriate way and has no aggravating circumstances, but the company must pay all disgorgement or forfeiture and restitution. Federal; all corporate criminal matters handled by the Department except antitrust violations under 15 USC 1-38. Declinations are made public.

   US Department of Justice — Corporate Enforcement and Voluntary Self-Disclosure Policy (department-wide) · Part I and disgorgement section · In force from 10 March 2026 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

   The 10 March 2026 date comes from the link label on the Criminal Division corporate enforcement page; the policy document itself shows no date.

10. In the UK a worker's disclosure is protected if the worker reasonably believes it is in the public interest and shows a criminal offence, a breach of a legal obligation, a miscarriage of justice, danger to health or safety, damage to the environment, sexual harassment, or deliberate concealment of any of these. Public Interest Disclosure Act 1998 provisions in the Employment Rights Act 1996. Disclosures are protected when made to the employer, a legal adviser or a prescribed person such as a regulator, and to others such as the media only in limited circumstances.

    GOV.UK — Whistleblowing: guidance for workers · Qualifying disclosures; who to tell · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Page metadata shows last updated 16 October 2026.

11. The SEC whistleblower programme pays awards of 10% to 30% of the money collected in SEC enforcement actions with over USD 1 million in sanctions to individuals who voluntarily provide high-quality original information, and the SEC can take action against employers that retaliate. Federal; Dodd-Frank Act. Award applications are due within 90 calendar days of a Notice of Covered Action.

    US Securities and Exchange Commission — Whistleblower awards · Programme description · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

12. The Department of Justice Corporate Whistleblower Awards Pilot Program pays eligible whistleblowers a share of forfeited assets for original information on corporate misconduct in areas including foreign corruption, sanctions violations, and trade, tariff and customs fraud; a company that self-reports within 120 days of an internal whistleblower report, and before the Department contacts it, may still qualify for a declination. Federal; Department of Justice Criminal Division. Awards are discretionary. Programme guidance was updated in July 2026.

    US Department of Justice, Criminal Division — Criminal Division Corporate Whistleblower Awards Pilot Program · Subject areas and company self-reporting · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

13. Employers that generally have at least 50 employees must set up and operate at least one internal whistle-blowing channel under the Whistleblower Protection Act (HinSchG). Certain financial and investment firms are covered regardless of headcount (§ 12(3)). Employers with 50–249 employees may share a channel (§ 14(2)); their transitional period ended on 17 December 2023.

    Bundesministerium der Justiz und für Verbraucherschutz / Bundesamt für Justiz (gesetze-im-internet.de) — Hinweisgeberschutzgesetz (HinSchG) · §§ 12, 14 and 42 HinSchG · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

14. A German internal reporting office must confirm receipt of a report to the whistle-blower within seven days and give feedback on planned and completed follow-up within three months of that confirmation. HinSchG section 17(1) and (2). Where no confirmation was sent, the three months run from three months and seven days after receipt. Anonymous reports should also be processed (section 16(1)), though channels need not be designed for anonymous reports.

    Federal Ministry of Justice (gesetze-im-internet.de) — Hinweisgeberschutzgesetz (HinSchG) · Sections 16 and 17 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

15. A commercial organisation that supplies goods or services, carries on all or part of its business in the UK and has annual turnover of £36 million or more must publish an annual modern slavery statement. Turnover includes subsidiaries and excludes VAT and trade discounts. Adding the statement to the government registry is encouraged but not required.

    Home Office — Publish an annual modern slavery statement · Who needs to publish · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

16. A presidential memorandum of 23 July 2026 directs the US Trade Representative to impose Section 301 tariffs on all goods of 60 economies found to have failed to prohibit imports made with forced labour, at 10 percent or 12.5 percent, or on a net-of-MFN basis for the EU, Taiwan, Japan, Korea and Switzerland. Federal. Products listed in an annex are exempt; tariff-rate quotas are to be set for certain textiles and apparel from Bangladesh, Cambodia, Indonesia and Malaysia. No end date is set and USTR may modify or terminate the tariffs.

    Executive Office of the President (Federal Register document 2026-15274) — Actions by the United States in the Investigations Under Section 301 of the Trade Act of 1974 of the Acts, Policies, and Practices of 60 Economies Related to the Failure of Each Economy To Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced With Forced Labor · Sections 1 and 2 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Read on the FederalRegister.gov web edition, which describes itself as unofficial; the official text is the Federal Register PDF on govinfo.gov. The effective date of the tariffs and the annex of exempt products (published as images) could not yet be checked. USTR's Section 301 page also lists other 2026 investigations, including structural excess capacity in manufacturing (initiated 11 March 2026).

17. The Supply Chain Due Diligence Act (LkSG) applies to companies with their head office, principal place of business or registered seat in Germany, or a German branch, that generally employ at least 1,000 employees in Germany. Threshold applies from 1 January 2024 (previously 3,000). Group companies' German employees count towards the parent's headcount; agency workers count after six months.

    Bundesministerium der Justiz und für Verbraucherschutz / Bundesamt für Justiz (gesetze-im-internet.de) — § 1 LkSG – Anwendungsbereich · § 1(1) and (3) LkSG · In force from 1 January 2024 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

18. Directive (EU) 2024/1760 on corporate sustainability due diligence, as adopted on 13 June 2024 and in force from 25 July 2024, covers EU companies with more than 1,000 employees on average and net worldwide turnover above EUR 450 million, and non-EU companies with net turnover in the EU of at least EUR 450 million. Thresholds must be met in each of the last two consecutive financial years (EU companies) or the financial year before the last (non-EU companies); there is no employee threshold for non-EU companies. Thresholds as stated in recitals 27 to 30 of the original text.

    EUR-Lex (Publications Office of the European Union) — Directive (EU) 2024/1760 on corporate sustainability due diligence · Recitals 27 to 30; document metadata · In force from 25 July 2024 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    Read from the original Official Journal text, not a consolidated version. Later amendments to scope or obligations under the EU omnibus simplification package, if adopted, were not confirmed.

19. FinCEN's final beneficial ownership information (BOI) rule, effective 14 August 2026, permanently exempts US companies from BOI reporting and removes the need to report US persons as beneficial owners. Federal rule under the Corporate Transparency Act. Applies nationwide; makes permanent the exemptions first introduced by the interim final rule of 26 March 2025.

    Financial Crimes Enforcement Network (FinCEN), US Department of the Treasury — Beneficial Ownership Information Reporting · Page banner and update notice (page updated 11 August 2026): final rule effective 14 August 2026 · In force from 14 August 2026 · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    Final rule published in the Federal Register on 14 August 2026 (document 2026-16576); the Federal Register page was seen in search results but not yet checked.

20. Legal entities under private law and registered partnerships must obtain, keep up to date and report details of their beneficial owners electronically to the registry authority for the Transparency Register without delay. Applies to German companies (including GmbH and UG) and registered partnerships; certain foreign entities are also covered (see de-regulatory-003).

    Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) — § 20 GwG – Transparenzpflichten im Hinblick auf bestimmte Vereinigungen · § 20 Abs. 1 GwG · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    § 20 Abs. 2 as displayed contains no notification fiction (Mitteilungsfiktion); an active report is required.

21. Companies must keep a register of beneficial owners and submit any change in beneficial ownership information to the registrar within 15 days of the change. Entities covered by Cabinet Resolution No. 109 of 2023. Administrative penalties for breaches are set by Cabinet Resolution No. 132 of 2023 (not reviewed here).

    UAE Legislation Platform — Cabinet Resolution No. (109) of 2023 Regulating the Real Beneficiary Procedures · Articles 8(1) and 15(2) · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

22. UK financial sanctions licences are issued by the Office of Financial Sanctions Implementation (OFSI), and trade sanctions licences by the Office of Trade Sanctions Implementation (OTSI) or the Export Control Joint Unit; without an exception, any prohibited activity needs a licence. Transfers of funds to or through a designated person can engage both financial and trade sanctions.

    GOV.UK — How to use exceptions and licences to comply with sanctions · Licensing bodies · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

23. A licence is needed to export dual-use items listed on the UK Strategic Export Control Lists from Great Britain; in Northern Ireland the EU Dual-Use Regulation (EU) 2021/821 applies instead. Licences include standard individual export licences and open general licences registered through SPIRE; the Export Control Joint Unit handles strategic export licensing queries. Moving controlled dual-use items from Northern Ireland to the EU or Great Britain needs no licence.

    Export Control Joint Unit — Export controls: dual-use items, software and technology, goods for torture and radioactive sources · Licensing; Northern Ireland · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

24. Under OFAC's 50 percent rule, entities owned 50 percent or more in the aggregate, directly or indirectly, by one or more blocked persons are themselves treated as blocked, even if not named on the sanctions list. Federal; OFAC programmes. Indirect ownership through other entities counts. Control without majority ownership is not captured by the rule but can still create risk.

    US Department of the Treasury, Office of Foreign Assets Control — Frequently Asked Questions (featured FAQ 401, Entities Owned by Blocked Persons) · FAQ 401 as featured on the FAQ index · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

    Only the question text and opening of FAQ 401 were visible on the index page; the full FAQ page could not yet be checked. The point on control is general knowledge, not from the page.

25. Items subject to the Export Administration Regulations include all items in the United States, all US-origin items wherever located, certain foreign-made items incorporating controlled US-origin content above de minimis levels and certain foreign-produced direct products, and items subject to the EAR but not listed on the Commerce Control List are designated EAR99. Federal, 15 CFR 734.3(a) and (c), administered by the Bureau of Industry and Security. Whether a licence is needed depends on the item's classification, destination, end user and end use. Defence articles under ITAR are outside this claim.

    Office of the Federal Register (eCFR) — 15 CFR 734.3 Items subject to the EAR · Section 734.3(a) and (c) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register.

26. An authorisation is required to export dual-use items listed in Annex I to Regulation (EU) 2021/821. Dual-use items listed in Annex I.

    EUR-Lex (Publications Office of the European Union) — Regulation (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items (recast) · Article 3(1) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

27. Any person in the UAE must freeze, without prior notice, funds owned or controlled by persons on the UN Sanctions List or the UAE Local Terrorist List within 24 hours of the listing decision. Applies to all persons in the UAE; financial institutions and designated non-financial businesses must also screen records and transactions (Article 21).

    Ministry of Economy and Tourism (publisher) — Cabinet Decision No. 74 of 2020 Regarding the UAE List of Terrorists and Implementation of UN Security Council Decisions · Articles 1 (definition of Without Delay) and 15(1) · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

28. It is a defence to the failure to prevent fraud offence for the organisation to prove that it had reasonable fraud prevention procedures in place, or that it was not reasonable to expect it to have any.

    legislation.gov.uk (The National Archives) — Economic Crime and Corporate Transparency Act 2023, section 199 · Section 199(4) · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed