A few days after three employees of Guralp Systems Limited, a U.K. seismic device company, were acquitted of charges of conspiracy to bribe a South Korean government official, the U.K.’s Serious Fraud Office (SFO) announced that the company had entered into a £2 million DPA, in which it agreed that its employees had in fact bribed the Korean official. The apparent contradiction between the two December 2019 events roused some commentary in the legal community. In a guest article, Sacha Harber-Kelly, a partner at Gibson Dunn, and Steve Melrose, an associate, dive deep into the details of the Guralp DPA and discuss whether the case represents a significant shift in enforcement for the SFO. See “Osofsky’s American Dream for the SFO” (Feb. 20, 2019).