SFO Co‑Operation Guidance: Investigation Expectations

When the SFO recently announced new guidance on how companies can avoid prosecution, much of the focus was on strongly encouraging self-disclosure of possible wrongdoing. However, in the SFO External Guidance on Corporate Co‑Operation and Enforcement in relation to Corporate Criminal Offending (2025 Guidance), the U.K. regulator also provided details on what it expects from companies in terms of cooperation during an investigation. This second article in a two-part series distills insights from London-based attorneys on how companies should think about cooperation credit. The first article examined the ways in which the 2025 Guidance encourages companies to self-report possible wrongdoing. See “2024 in Review: International Cooperation Continues to Drive ABAC Enforcement” (Dec. 18, 2024).

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