SFO’s new “adequate procedures” guidance: an opportunity missed?

The Serious Fraud Office (“SFO”) published new internal guidance to assist its staff in evaluating an organisation’s compliance programme as part of an investigation, and assessing how that programme may impact on prosecution and deferred prosecution agreement (“DPA”) decisions. Although internal, it provides a useful reminder for corporates of the value and potential importance of implementing effective anti-bribery controls, and having effective compliance records in place.