SFO Internal Guidance on Evaluating a Compliance Programme

On 17 January 2020 the UK Serious Fraud Office (“SFO“) updated its Operational Handbook to include a new chapter on evaluating a compliance programme (the “New Chapter“). The New Chapter considers the relevance of compliance programmes for SFO cases and how the SFO will investigate the effectiveness of a compliance programme.

The SFO’s Operational Handbook is for internal SFO guidance, does not constitute official guidance to third parties and is published in the interests of transparency. However, it can be instructive in revealing the SFO’s approach to certain matters. In this briefing we provide an overview of the New Chapter. Continue reading