August 30, 2019

New Corporate Co-operation Guidance from the UK Serious Fraud Office: Convergence and Divergence between the US and UK Regimes


The UK Serious Fraud Office (“SFO”) published new “Corporate Co-operation Guidance” (the “Guidance”) on 6 August 2019.  In doing so, the SFO provided a greater degree of clarity as to its expectations of organisations seeking co-operation credit.  In particular, the Guidance lists a number of specific factors that the SFO will take into account when considering the level of co-operation by an organisation under investigation, which will directly impact the decision whether to charge a company or initiate negotiations for a Deferred Prosecution Agreement (“DPA”) in lieu of prosecution.

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