self-reporting

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The updated guidance puts a heavy emphasis on self-reporting and clarifies how corporates under investigation can earn cooperation credit from UK prosecutors.

By Pamela Reddy, Clare Nida, Annie Birch, and Matthew Unsworth

On 24 April 2025, the UK Serious Fraud Office (SFO) published a long-awaited update to its Guidance on Corporate Co-operation and Enforcement (the Guidance). The Guidance outlines the agency’s key considerations when deciding whether to prosecute a corporate or invite it to negotiate a deferred…

Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations.

By Stuart Alford QC, Nathan H. Seltzer, Christopher M. Ting, and Harriet Slater

On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate Cooperation Guidance (the Guidance) outlining, in substantial detail, the steps that the SFO expects corporations to undertake in order to be eligible for cooperation credit when the SFO makes charging decisions, including in relation to whether a deferred prosecution agreement would be appropriate in lieu of full criminal prosecution.

In many respects, the Guidance is unsurprising and provides the types of investigative best practices that sophisticated companies and their advisers are already familiar with – particularly companies familiar with US regulators’ expectations regarding cooperation credit.

By Dan Smith and James Fagan

On 25 September 2015 the United Kingdom saw its first disposal of the offence of failure by a commercial organisation to prevent bribery under section 7 of the Bribery Act 2010 (the “Failure Offence”). The Civil Recovery Unit of the Scottish Crown Office and Procurator Fiscal Service has reported that it has recovered £212,800 under an agreed civil settlement with Brand-Rex Limited, a developer of industrial and network cabling solutions based in Scotland.