Defence integrity under the UK’s Anti-Corruption Strategy – what businesses should do now

The defence sector combines scale, urgency and confidentiality in a way that makes corruption and conflicts risk unusually hard to spot – and unusually costly when it goes wrong. This risk is amplified by the relatively high percentage of defence contracts which are awarded directly. The Strategy identifies that, while a sustained increase in defence spending is necessary for national security, it “heightens the risk of corruption”. It seeks to address this through commitments which focus on capability and structures, specifically: continued investment in the Building Integrity UK Programme (including training and support for UK partners and NATO-aligned initiatives); the establishment of the National Armaments Directorate (NAD) as part of wider procurement reform; and strengthened vetting and insider-risk measures, including a joint vetting centre and improved data capability intended to monitor, detect and (where possible) predict insider risk.

Those measures are sensible. But the criticism from commentators including Transparency International, put neutrally, is that they do not directly target the scenarios where corruption and conflicts typically arise – especially where full transparency is not possible and timelines are compressed.

In addition, the Strategy's defence case study places particular emphasis on overseas risks, including in jurisdictions where issues with state capture arise, and the way defence-sector corruption can worsen conflict dynamics and enable abuses. That angle is important, but it can also risk obscuring the domestic question: what practical guardrails will govern access to and conflicts in UK-facing contracts, particularly where timelines are short, supplier markets are often small and transparency is constrained?

Analysis – what the Strategy addresses and what it leaves unresolved

Access and conflicts

The Strategy puts understandable emphasis on vetting and insider risk, and there are 49 references to procurement in the document. But a bigger practical question in the defence sector is often what happens when people leave the public sector and re-enter the ecosystem as advisers or intermediaries – and can secure preferential access because of their prior roles and relationships. Identifying and managing conflicts of interest, whether through the Procurement Act 2023 or otherwise, is a key priority.

That matters most when contracting becomes urgent. Time pressure and confidentiality can reduce time for compliance checks, lessen scrutiny and increase reliance on informal networks, creating avoidable conflicts and a weak evidential record of why a decision was taken. Recent reporting and investigations concerning alleged corruption in procurement at NATO's Support and Procurement Agency (NSPA) underscore the point: exposure can arise less from the formal rules than from access, intermediaries and non-transparent relationships operating at the margins of the process.

Transparency International UK has pointed to the breadth of overlap between prior official responsibilities and subsequent roles: in its analysis, 81% of post-public employment moves reviewed involved overlap between the individual's previous brief and their new position. That is a reminder that, in a sector where access can be commercially decisive, even lawful engagement can create perception and integrity risks, unless conflicts are managed (and suppliers excluded from contracts where conflicts cannot be addressed in another way) and the rationale for decisions is properly documented.

The practical response is not to avoid legitimate engagement, but to treat access as a controlled process. For contracting authorities, that means disciplined market engagement, clear rules on contacts and meetings, ongoing conflicts assessments, the use of the exclusions regime in procurement law, recusals (including around evaluation and change-control), and records that evidence why decisions were taken. For suppliers, it means a defensible engagement model – defined channels for contact, careful use of advisers and introducers, and an audit trail that can withstand later scrutiny, particularly where programmes evolve quickly and decisions are revisited through post-award changes. There is a risk of debarment from public contracts where suppliers get this wrong, although this regime is new and, as yet, untested.

Multi-agency coordination, supplier eligibility – and the enforcement question

The Strategy refers to the Procurement Act 2023 regime (in force since February 2025), which strengthens exclusion rules for suppliers bidding for public defence contracts and introduces a ministerial debarment list, maintained by the Cabinet Office. It also claims that the creation of the NAD will “improve the effectiveness of defence procurement and better enable the MOD to mitigate the associated corruption risks”, by bringing defence buying under one roof – one strategic authority, one budget, clearer decision-making and oversight. But the Strategy says little about how defence sector integrity will be coordinated across governmental departments and different agencies.

There is also an elephant in the room for many businesses: in sensitive, national-security contexts, how tough will UK enforcement agencies be in practice when allegations touch defence programmes or strategically important contractors? The new direct award ground on the basis of national security in the Procurement Act is untested and there is often a piecemeal approach to managing sensitive information. Even with strong policy intent, enforcement posture is shaped by operational realities – classified material, diplomatic sensitivities, and the need to keep things progressing.

But this is an area where enforcement priorities can shift quickly. In this context, the U.S. Department of Justice's June 2025 FCPA guidance, issued after the enforcement pause, signalled a more interest-driven approach – prioritising cases that implicate US national security and competitiveness (including where corrupt conduct disadvantages US businesses) and cautioning against “over-enforcement”. UK agencies may face similar questions as defence procurement accelerates.

Whistleblowing and intelligence – why defence will be a key test case

The Strategy nods to the possibility of stronger whistleblowing frameworks and, in some areas, this is already happening – as reflected in HMRC's expanded reward framework for serious tax avoidance or evasion.

The defence sector is one area where any whistleblowing reforms will be particularly interesting, given the sensitivity of information and the risk that disclosures intersect with clearance, confidentiality, classification and contested judgement calls.

In practice, that means businesses in the defence sector should put renewed focus on how their whistleblowing channels operate. It will be increasingly important to be able to demonstrate not only what suppliers are doing in this area, but also how they will deliver it.

Urgent capability and emerging technologies

The Strategy correctly states that “the inherent secrecy and complexity of the defence sector” makes it vulnerable to corrupt actors, but it does not address how those factors are amplified in urgent situations where time is of the essence – particularly in fast-moving areas such as cyber, data and AI-enabled systems.

Governments and defence organisations are increasingly reliant on private-sector innovation in this space, including newer, AI-native vendors and platforms, rather than purely in-house capability.

Urgency, together with the need for confidentiality, narrows the supplier pool and compress due diligence, while intermediaries and specialist advisers may sit closer to sensitive decisions. In addition, value (and risk) often sits in updates, maintenance, managed services, and post-award changes, not just the initial award. In this environment, integrity means getting clear as soon as possible on who is actually in the delivery chain, how fees are structured, what will change over time, and how post-award contract management and modifications are governed. 

Conclusion

The Anti-Corruption Strategy is a useful marker of intent: it identifies defence as a priority, and its focus on resilience and insider risk reflects genuine vulnerabilities. Those measures should go some way to reducing corruption and insider risk exposure in the sector. They are unlikely, on their own, to eliminate the underlying risks – particularly where procurements are urgent, not always subject to competition, information is confidential and sensitive, and access and conflicts sit at the edge of the formal process.

Suppliers should also assume that defence will remain a focus area for UK and international agencies. The U.S. Department of Justice's recent change in approach, with a stated emphasis on national security and competitiveness considerations, is a reminder that enforcement priorities can shift quickly and may increasingly track strategic sectors.

In that environment, the sensible course is for businesses to ensure their understanding of the relevant legal regimes (particularly in relation to procurement), and refresh controls and guardrails now so that they are prepared for scrutiny when it comes.

For more information or advice on this topic please contact Liam Naidoo, David Hansom or Reuben Vandercruyssen.

Authored by Reuben Vandercruyssen, Liam Naidoo, and David Hansom.