On April 24, 2025, the UK Serious Fraud Office issued new corporate co-operation guidance that states, for the first time, that companies that promptly self-report suspected corporate wrongdoing can expect to be offered to negotiate a Deferred Prosecution Agreement (“DPA”) rather than face prosecution, provided that the company fully co-operates with investigators and exceptional circumstances do not apply. The new corporate co-operation guidance, which was introduced by the SFO Director at a legal conference in London, also intends to make it simpler for companies to report suspected wrongdoing directly to the SFO through a secure reporting portal. The guidance also provides advice regarding the decision to self-report, clarifies what the SFO views as “genuine cooperation,” and gives examples of what is considered to be uncooperative conduct. According to the guidance, in response to any corporate inquiry or self-report, the SFO intends to:
• Respond within 48 business hours.
• Provide regular updates to self-reporting companies through the process.
• Decide whether or not to open an investigation within six months of a self-report.
• Conclude investigations promptly.
• Conclude DPA negotiations within six months of sending an invite.
UK Government Press Release | SFO Corporate Guidance