The swinging pendulum of SFO self-reporting policy

In a move reminiscent of the 2009 corporate self-reporting guidelines for overseas corruption, on 24 April 2025, the SFO issued new Guidance stating that “if a corporate self-reports promptly…and cooperates fully, we will invite it to negotiate a DPA rather than prosecute, unless exceptional circumstances apply”. The 2025 Guidance is not quite as favourable as […]