A Comparative Review of the SFO’s Internal Guidance on DPAs

The SFO recently published a chapter from its internal Operational Handbook setting out the SFO’s internal guidance and approach to DPAs. In a guest article, Judith Seddon, Sarah Lambert-Porter and Zaneta Wykowska of Ropes & Gray analyze the most salient insights provided from the revised chapter, highlighting the divergences and confluences of the prosecutorial approach of the U.K. and U.S. DPA regimes and their relevance for companies trying to decide whether and when to self-report with a view to entering into DPA negotiations. For more from Ropes, see “Encouraging Internal Reporting to Mitigate COVID 19-Related Risk” (Jul. 22, 2020).

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