SFO Co‑Operation Guidance: A Hard Sell for Self-Reporting

On April 24, 2025, the SFO issued External Guidance on Corporate Co-Operation and Enforcement in relation to Corporate Criminal Offending (2025 Guidance), which seeks to provide additional clarity and certainty to companies considering self-reporting criminal wrongdoing. The 2025 Guidance has plenty of wiggle room built in, however, leaving companies with tough decisions to make about whether to come forward. The Anti-Corruption Report spoke with practitioners in London about the implications of the 2025 Guidance. This first article in a two-part series discusses the impact on self-reporting. Part two will examine the SFO’s expectations for corporate cooperation. See “The International Anti-Corruption Taskforce and U.S. FCPA Enforcement: A Look Ahead” (May 7, 2025).

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