With the Serious Fraud Office (SFO) promising a warmer welcome for corporates that self-report misconduct, does its newly published External Guidance on Corporate Cooperation and Enforcement mark a turning point in corporate criminal enforcement?
Partner Richard Sallybanks, alongside associates Megan Curzon and Matt Davies, talk to Fraud Intelligence, weighing in on whether the SFO’s revised approach, underpinned by clear timelines, updated cooperation standards, and a "cast iron guarantee" of a Deferred Prosecution Agreement (DPA) will shift corporate behaviour.
The article unpacks key issues, including:
- The risks and benefits of self-reporting
- What counts as ‘full’ or ‘exemplary’ cooperation?
- The growing criminal exposure under the Economic Crime and Corporate Transparency Act 2023
Despite the SFO’s push, with only 12 DPAs concluded since 2014, Fraud Intelligence ask whether the incentives are strong enough to encourage change or whether silence may still feel like the safer option for some.
This article was first written for and published by Fraud Intelligence on 14 June 2025. To read the full article, please click here.
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