Ultra Electronics Holdings Ltd (UEH) and its subsidiaries’ recent settlement of bribery allegations with the SFO, illustrate how a failed, outdated compliance program can be overhauled post-acquisition to meet SFO expectations and result in a DPA with limited penalties. This second article in a two-part series dissecting the settlement examines UEH’s compliance failures and the significant remediation efforts it undertook after its acquisition. The first part analyzed the background of the case, the behaviors that brought UEH under scrutiny and its cooperation with the SFO. See our two-part series on the SFO’s Co-Operation Guidance: “A Hard Sell for Self-Reporting” (May 21, 2025), and “Investigation Expectations” (Jun. 4, 2025).