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Clifford Chance
Briefings

Briefings

Consumer Goods & Retail Sector: UK corporate criminal liability reforms: risks for global supply chains

8 May 2026

Reforms to the UK's law on corporate criminal liability which will come into effect on 29 June 2026 will increase the risk of prosecution for businesses with complex global supply chains. Multinational organisations will be potentially criminally liable for the actions of certain individuals within them. They should review their supply chain operations and governance arrangements now and identify and address any weaknesses that could give rise to UK enforcement action.

Supply chain compliance depends on all participants identifying and addressing risks and meeting their legal and regulatory obligations across sourcing, manufacturing, distribution and marketing operations. For consumer goods and retail businesses, the risk of criminal investigations and enforcement action is particularly pronounced in the UK, the US, France and Italy. Implementing clear policies, conducting regular reviews of supply chain processes and putting in place thorough training arrangements across all relevant jurisdictions are therefore essential.

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