SFO Compliance Guidance Distills but Does Not Illuminate Enforcer Expectations

On the heels of its long-awaited Corporate Co-operation Guidance, issued in August 2019, the U.K. Serious Fraud Office (SFO) published guidance in January 2020, Evaluating a Compliance Programme. Taken together, the two documents show that under Director Lisa Osofsky the SFO is willing to provide guidance to companies on matters like compliance and cooperation – issues that feature heavily in recent anti-corruption settlements such as Guralp and Airbus – a move which former head of the SFO David Green resisted. However, in many ways, the new compliance guidance is simply a distillation of previous practice and compliance expectations. The Anti-Corruption Report spoke with U.K. practitioners to assess to what extent the new guidance illuminates SFO expectations and how companies should react accordingly. See our three-part series on the SFO’s Co-Operation Guidance: “Transparency” (Sep. 18, 2019); “Waiving Privilege” (Oct. 16, 2019); and “Internal Investigation Expectations” (Nov. 13, 2019).

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