The life sciences and health care sector faces elevated risks for bribery and corruption, making robust compliance and prevention programs essential. In 2025, changes in anti-corruption enforcement around the globe created new priorities, new rules, and new enforcement risks for life sciences and companies must adapt their compliance efforts to respond.

The U.S: A 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. When the Department of Justice 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.

The UK: New fraud offense

Across the pond, in September 2025, the United Kingdom implemented a new strict liability offense: "Failure to Prevent Fraud." The law casts a wide jurisdictional net, covering misconduct with any UK nexus, leaving foreign multinationals with UK touchpoints exposed. Organizations must implement "reasonable" procedures to defend against allegations.

China: Tightening controls

In January 2025, China issued its first industry‑specific anti‑corruption and anti‑monopoly guidelines for pharmaceutical and medical device companies. The new framework addresses conduct not previously regulated by the State Administration for Market Regulation, including collusion to monopolize pharmaceutical markets and share profits derived from those arrangements.

Cross-border: The rise of coordinated enforcement

Global enforcement cooperation has grown substantially. In March 2025, enforcement authorities in the UK, France, and Switzerland created the International Anti‑Corruption Prosecutorial Taskforce. This cross‑border partnership increases the likelihood that misconduct in one jurisdiction will trigger scrutiny in others, raising the stakes for multinational life sciences companies.

What compliance leaders must do

Although the U.S.'s role in international anti-corruption enforcement may have shifted, global enforcement activity and multinational cooperation is expected to rise. Life sciences companies should invest in comprehensive compliance programs that include auditing and monitoring, employee training, and enhanced third‑party due diligence. Strong compliance is both a financial safeguard and a moral obligation in an industry where patient trust and public health are paramount.