London Associate André Nwadikwa Discusses Expanded Corporate Criminal Liability in Global Investigations Review
Associate André Nwadikwa shared his insights with Global Investigations Review on the significant expansions to UK corporate criminal liability introduced by the new Crime and Policing Act 2026. From 29 June 2026, companies will be responsible for any criminal offence committed by a “senior manager” acting within their actual or apparent authority—without any requirement that the company had benefitted and even with a robust compliance programme in place.
André told GIR that the new senior manager test looks at an employee's actual functions within an organisation, rather than their job title, expanding the corporate prosecution risk “from the boardroom to across the entire organisation.”
André also cautioned that "companies are likely to have more senior managers than they think that attract this level of risk and who can therefore make decisions that bind the company."
A former prosecutor, André Nwadikwa leverages his experience in bringing cross-border, large-scale cases to trial in advising clients facing the full spectrum of government enforcement investigations in the United Kingdom, United States of America, and beyond.
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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
Associate André Nwadikwa shared his insights with Global Investigations Review on the significant expansions to UK corporate criminal liability introduced by the new Crime and Policing Act 2026. From 29 June 2026, companies will be responsible for any criminal offence committed by a “senior manager” acting within their actual or apparent authority—without any requirement that the company had benefitted and even with a robust compliance programme in place.
André told GIR that the new senior manager test looks at an employee's actual functions within an organisation, rather than their job title, expanding the corporate prosecution risk “from the boardroom to across the entire organisation.”
André also cautioned that "companies are likely to have more senior managers than they think that attract this level of risk and who can therefore make decisions that bind the company."
A former prosecutor, André Nwadikwa leverages his experience in bringing cross-border, large-scale cases to trial in advising clients facing the full spectrum of government enforcement investigations in the United Kingdom, United States of America, and beyond.
Related Attorneys
Related Capabilities
Related Locations
© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
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