Caroline Black featured in Compliance Week on new SFO compliance guidance

Caroline Black, Consultant at Gherson Solicitors, has been featured in Compliance Week commenting on the UK Serious Fraud Office’s (SFO) updated guidance on how it evaluates corporate compliance programmes.

The article, “SFO guidance on evaluating compliance programs short on specifics, experts say”, examines the SFO’s recently published guidance and the concerns raised by practitioners that it falls short of providing a clear or prescriptive roadmap for organisations seeking certainty.

Caroline highlights that, despite the lack of detailed benchmarks, the guidance gives important signals about what the SFO expects in practice. Having worked with a number of companies going through an SFO investigation for a “failure to prevent” offence, she emphasises that organisations should be proactive and evidence-led in preparing for potential scrutiny. This should include undertaking meaningful compliance effectiveness reviews, strengthening documentation and processes, improving fraud and bribery frameworks and ensuring that compliance is supported by leadership and embedded in corporate culture.

As Caroline notes in the article, companies should not treat compliance as a tick-box exercise but should be ready to demonstrate how their programmes operate in reality across relevant jurisdictions and over time. This practical, lived approach is likely to be critical when the SFO is deciding whether to prosecute, offer a deferred prosecution agreement or make sentencing submissions.

The article was originally published in Compliance Week: “SFO guidance on evaluating compliance programs short on specifics, experts say.”

Read more in our previous blog: SFO guidance on evaluating corporate compliance programmes (2025)

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