Tag Archives: Lloyd Firth

UK Serious Fraud Office Issues New Self-Reporting and Corporate Cooperation Guidance

by Lloyd Firth and Frederick Saugman

Left to right: Lloyd Firth and Frederick Saugman (photos courtesy of Wilmer Cutler Pickering Hale and Dorr LLP)

On 24 April 2025, the UK Serious Fraud Office (SFO) issued new guidance to encourage companies to self-report suspected corporate wrongdoing. The guidance states that self-reporting, combined with full cooperation with the SFO’s investigation will, absent exceptional circumstances, lead to the SFO inviting the company to commence Deferred Prosecution Agreement (DPA) negotiations.[1] While the guidance is a welcome recognition that companies crave certainty of outcome in their dealings with the SFO and a sign of the agency’s increased pragmatism, in practice it is unlikely to move the needle for companies on notice of suspected wrongdoing facing the critical strategic decision of whether and when to self-report.

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UK, French, and Swiss Enforcement Authorities Announce New Alliance

by Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno, Kimberly A. Parker, Jay Holtmeier, Erin G.H. Sloane, Christopher Cestaro, and Lindsey Cullen

Top left to right: Lloyd Firth, Dr. Jan-S. Wendler, Claire M. Guehenno and Kimberly A. Parker. Bottom left to right: Jay Holtmeier, Erin G.H. Sloane, Christopher Cestaro and Lindsey Cullen (Photos courtesy of WilmerHale).

Summary

Anti-bribery and corruption agencies in the UK, France and Switzerland recently announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration.

This taskforce was announced by the UK’s Serious Fraud Office (SFO), France’s Parquet National Financier (PNF) and the Office of the Attorney General of Switzerland (OAG) at a meeting in London. Its founding statement notes “the significant threat of bribery and corruption” and states that its members recognise that “success relies on us working closely and effectively together”. It intends to deliver a working group for case cooperation and increased best practice sharing.

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UK Serious Fraud Office Publishes Corporate Co-operation Guidance

By Stephen Pollard, Christopher David, Lloyd Firth, and Leila Gaafar

On 6 August 2019, the UK Serious Fraud Office (‘SFO’) published Corporate Co-operation Guidance (‘Guidance’)[1].  This Guidance is designed to assist companies considering whether to self-report corporate wrongdoing to the SFO and, if so, how to achieve maximum co-operation credit to help avoid prosecution, or be offered the opportunity to enter into a Deferred Prosecution Agreement (‘DPA’).  In doing so, it clarifies the SFO’s position on various key investigative themes, including: data gathering and production; the company’s dealings with individual witnesses and suspects; and the implications of asserting legal professional privilege (‘Privilege’) over witness accounts obtained during an internal investigation. Continue reading →