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Serious Fraud Office (SFO) Deferred Prosecution Agreements Corporate Crimes

Seyfarth Shaw LLP

Updated SFO Guidance: Familiar Framework, Sharper Focus—Timing Is Everything

Seyfarth Shaw LLP on

The Serious Fraud Office (SFO) is raising the stakes. With the publication of new Co-operation and Enforcement Guidance on 24 April 2025, the agency is ramping up enforcement and clarifying expectations for corporate...more

Hogan Lovells

SFO's new self-reporting guidance: A new deal or a departure from justice?

Hogan Lovells on

On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...more

Society of Corporate Compliance and Ethics...

UK Serious Fraud Office releases DPA guidance

CEP Magazine (January 2021) - The United Kingdom’s Serious Fraud Office published new guidance related to deferred prosecution agreements (DPAs). The guidance, nested in the office’s internal SFO Operational Handbook,...more

BCLP

The SFO, the Goose and the Golden Eggs: What the SFO’s New Guidance on DPAs Tells Us About the Prosecutor’s Approach to...

BCLP on

On 23 October 2020, the SFO published a chapter from its Operational Handbook, including an expanded section on corporate co-operation, so as to give “comprehensive guidance” on the organisation’s approach to the use of...more

White & Case LLP

Gazing into the crystal ball - what to expect from the SFO in 2020

White & Case LLP on

The SFO faced a challenging 2019, with some high-profile acquittals, dropped investigations and new cases which were widely perceived as relatively underwhelming. We look back at the last 12 months, and set out what might be...more

Skadden, Arps, Slate, Meagher & Flom LLP

Transatlantic Approach on Corporate Cooperation: How Newly Issued French and UK Guidance Compare to US Practices

As widely anticipated, French and U.K. regulators recently published guidance detailing their expectations for corporate cooperation in enforcement investigations. Both sets of guidance demonstrate further alignment of those...more

BCLP

SFO Corporate Co-operation Guidance – A flawed approach and a wasted opportunity

BCLP on

The much heralded Corporate Co-operation Guidance published by the Serious Fraud Office recently offers little comfort to corporates struggling with the dilemma of whether to self-report wrongdoing. Instead it offers a...more

White & Case LLP

Co-operation or Capitulation? – What the SFO Corporate Co-operation Guidance really means

White & Case LLP on

Is there a point at which co-operation becomes capitulation? Is there a danger inherent in co-operating without the guarantee of a favourable outcome for doing so?...more

Morrison & Foerster LLP

The UK’s Serious Fraud Office Issues Guidance for Corporate Cooperation

On 6 August 2019, the UK’s Serious Fraud Office (SFO) released Guidance on what it expects from organisations seeking cooperation credit in the agency’s investigations. The long-awaited Guidance is a codified and clarified...more

White & Case LLP

Deferred Prosecution Agreements 5 Years On – the Americanisation of UK Corporate Crime Enforcement

White & Case LLP on

Five years ago, in the spring of 2014, Deferred Prosecution Agreements ('DPAs') were first introduced in the UK through the Crime and Courts Act 2013 ('CCA').1 Since then, the Serious Fraud Office ('SFO') has concluded four...more

White & Case LLP

Tesco trial collapse highlights dangers of an early deferred prosecution agreement

White & Case LLP on

On 6th December 2018, the trial of two Tesco executives accused of false accounting collapsed. The judge concluded that the SFO's evidence, taken at its highest, was such that a jury could not properly convict. The SFO...more

BCLP

What enforcement tools are in the armoury of prosecutors in the US, UK and France?

BCLP on

Summary: Deferred prosecution agreements have been widely used by US prosecutors since the early 2000s. Prosecutors in the UK and France only obtained this power in 2014 and 2016 respectively – but they are making up for...more

WilmerHale

Criminal justice: How best to stop economic crime

WilmerHale on

Speaking at the 35th annual Cambridge International Symposium on Economic Crime, Robert Buckland QC MP, the Solicitor General for England and Wales, and David Green QC, Director of the SFO, addressed the question, “Preventing...more

WilmerHale

Less ‘boondoggle’, more ‘fair, reasonable and proportionate’: the use of corporate monitors in UK Deferred Prosecution Agreements

WilmerHale on

A common feature of corporate criminal disposal in the US for several decades, the use of corporate monitors in the UK in the same period has been, at best, sporadic. This was expected to change with the introduction of...more

Latham & Watkins LLP

Prosecuting Corporate Offending - A New Approach from the Serious Fraud Office

Latham & Watkins LLP on

Deferred prosecution agreements (DPAs) became part of the prosecutors’ toolbox in 2014, allowing for settlement instead of bringing a case to trial. Recent statements from the Serious Fraud Office (SFO) indicate an increasing...more

WilmerHale

The UK’s second DPA: a hopeful judgment

WilmerHale on

The approval of the Deferred Prosecution Agreement (DPA) between the Serious Fraud Office (SFO) and XYZ Limited (XYZ) by Leveson LJ on 8 July 2016 has generated much breathless commentary, not least because it is only the...more

Akin Gump Strauss Hauer & Feld LLP

Corporate Bribery: Successful Prosecutions in the United Kingdom

In a busy week for the Serious Fraud Office (SFO), the United Kingdom’s antibribery prosecutor, it has announced its first-ever deferred prosecution agreement (DPA) for bribery offences and the first guilty plea under the...more

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