SFO updates self-reporting guidance - what the new direct line means for corporates
The SFO’s amended Corporate Cooperation Guidance gives companies’ lawyers direct access to its General Counsel before a formal self-report is made.
Frankie Williams, Associate in our Commercial Litigation team, has been quoted in the media on the news that the Serious Fraud Office (SFO) has published an updated version of its Corporate Cooperation Guidance (CCG) on the self-reporting of suspected fraud, bribery and corruption.
Published on 13 October, the amended guidance allows a corporate’s legal representatives to confer directly with the SFO’s Director of Legal Services and General Counsel, Matthew Wagstaff, about a planned self-report. A dedicated inbox is available for this, separate from the one used to submit a report. The update amends the original CCG, published in April 2025, and reinforces the SFO’s commitment to focus on negotiating a deferred prosecution agreement (DPA) where a company self-reports immediately and co-operates fully. The guidance also commits to a response within two business days of a report, frequent updates and a maximum six-month wait for a decision on whether to investigate.
Frankie viewed the change as a positive development overall, commenting: “Whilst the SFO has limited resources and there is also a limit to the commitments it can make, it has clearly set itself a challenge (as a responsible prosecutor) with this latest offer to corporates. This is a step in the right direction in terms of encouraging self-reporting, even if the level of take up remains to be seen.”
Read Frankie’s comments in the media:
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