New Guidelines in SFO’s Operational Handbook

The UK Serious Fraud Office has published new internal guidelines for how it evaluates the effectiveness of the companies it investigates.  The guidance is part of the SFO’s Operational Handbook.  The SFO will now consider 1) the state of the compliance program at the time of the offense, and 2) the current state of the compliance program.  In addition, if a Deferred Prosecution Agreement is considered, how the compliance program should change could become part of the DPA itself.

SFO Handbook - Compliance Programme Guide

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