SFO sharpens framework for judging compliance programs in bribery and fraud cases

The U.K. Serious Fraud Office (SFO) has updated its guidance about how it evaluates corporate compliance programs when considering whether to prosecute or offer leniency to companies that have breached bribery and corruption laws.

The agency hopes the new guidance will provide greater clarity about what the SFO expects from compliance and assurance functions for them to be considered following best practice. It stresses that having policies, procedures, and controls in place does not automatically mean a compliance program is effective. Instead, the SFO warns that it will “examine how policies translate into conduct on the ground” and states that “compliance issues will be considered early in the investigation.”

“Effective compliance is not a tick-box exercise,” said Matthew Wagstaff, the SFO’s director of legal services in a statement. “It’s about creating genuine cultures that prevent fraud, bribery, and corruption.”