By Saqib Alam, Shawna Pasquale and Amanda Aikman

On 17 January 2020, the UK’s Serious Fraud Office (the “SFO”) released guidance (PDF: 2.29MB)  on evaluating compliance programmes (the “SFO Guidance”). This is the first time the SFO has issued guidance on how it will assess the effectiveness of an organisation’s compliance  programme. Forming part of the SFO’s internal Operational Handbook, the SFO said it published the guidance in the interests of transparency and with the disclaimer that it should not be relied on as the basis for any legal advice or decision. The SFO Guidance nonetheless serves to assist organisations not only in evaluating the strength of their compliance programmes but also sets out what organisations can expect from the SFO and what remediation measures they should take in relation to their compliance programmes, if they are being investigated by the SFO. Continue reading →