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FIND OUT MOREPartner Duncan Grieve discusses whether the SFO’s new corporate compliance guidance provides greater clarity or transparency, the lessons companies can draw from it, and how it compares with approaches in other jurisdictions. Duncan’s comments were published in Compliance Week, 30 December 2025, and can be found here.
Does the SFO guidance provide greater clarity or transparency about the circumstances in which it will evaluate corporate compliance?
“The Guidance is effectively an update to prior guidance now encompassing the new failure to prevent fraud offence under section 199 of the Economic Crime and Corporate Transparency Act 2023 (which entered into force on 1 September 2025). Whilst the Guidance sets out scenarios in which authorities will evaluate a company’s compliance programme, it does so through reference to previously published guidance and relevant legislation.
“As such, it is a helpful restatement of established principles but does not provide significant further clarity on the assessment criteria for corporate compliance programmes. It does not, for example, contain a detailed framework against which organisations can benchmark their own policies and internal controls.”
What lessons might companies draw from the guidance?
“The Guidance serves as a reminder that the SFO will scrutinise and evaluate the effectiveness of corporate compliance programmes at every stage of an investigation and enforcement action. Although there might not be as much detail as the compliance community were hoping for, the publication of this Guidance along with the coming into force of the broad failure to prevent fraud offence on 1 September 2025, should prompt organisations to refresh and review their internal controls and check their effectiveness in practice.”
How does the guidance/SFO approach compare to those used in other jurisdictions?
“It is notable that the guidance refers to the more detailed guidance published by the U. S. Department of Justice and the French Agence Anti-Corruption (AFA), and recommends that organisations refer to this where they have a U. S. or French nexus. Given the greater level of detail contained in these guidance documents, many companies will continue to refer to these texts as they benchmark and pressure test their own compliance programs.”
