Freemium - Inside the SFO’s Corporate Compliance Playbook: How Companies Are Evaluated—and Why It Matters

In this episode, we unpack the Serious Fraud Office’s newly detailed guidance on how corporate compliance programmes are evaluated across England, Northern Ireland, and Wales. The SFO relies on this framework in six key scenarios—from deciding whether to prosecute a company to determining whether a Deferred Prosecution Agreement (DPA) is appropriate.We break down what the guidance means for organisations facing allegations of bribery or fraud, including how the SFO assesses statutory defences like “adequate procedures” for bribery and “reasonable procedures” for failure to prevent fraud. The conversation explores why the SFO places heavy emphasis on the effectiveness and proactive nature of compliance systems—both at the time of the offence and during charging decisions.You’ll also learn why the SFO warns companies against treating compliance as a superficial “paper exercise.” Instead, programmes must be risk-based, proportionate, and continuously reviewed, regardless of a company’s size or sector. Tune in to understand how these standards are reshaping corporate accountability in the UK.

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