SFO strengthens corporate cooperation guidance

The Serious Fraud Office (SFO) has today (13 October) strengthened its guidance for corporates on self-reporting suspected fraud, bribery and corruption, introducing a new route for legal representatives to communicate directly with the organisation’s Director of Legal Services.

The update, announced by Director of Legal Services and General Counsel Matthew Wagstaff at the International White Collar Institute in London, follows feedback from legal practitioners since the guidance was first revised in April 2025.

Under the change, corporate’s legal representatives will be able to discuss a potential self-report directly with Mr Wagstaff via a new dedicated email address, [email protected], before committing to a formal report.

Speaking at the event, hosted by the American Bar Association, Mr Wagstaff is expected to say:

We believe a swifter, clearer path to enter negotiations for a deferred prosecution agreement is in the best interests of everyone and so we’ve taken this feedback on board. That’s why, as of today, we are strengthening our guidance so that a corporate’s legal representatives can, if they wish, communicate directly with me before they formally submit a self-report.

The SFO’s Corporate Cooperation Guidance, first launched in April 2025, commits that corporates who report promptly and cooperate fully will, barring exceptional circumstances, be invited to enter negotiations for a Deferred Prosecution Agreement (DPA). The guidance sets out that the SFO will make contact within 48 business hours of a self-report, provide regular updates throughout the process, decide whether to open an investigation within six months, and aim to conclude investigations within a prompt timeframe.

As a responsible prosecutor, there will rightly always be limits to the commitments that we can make. Nevertheless, I believe that in this guidance we have challenged ourselves as an organisation to make the strongest possible offer to responsible corporates.