Beyond the Binder: SFO’s New Rulebook Requires Operational Evidence
Introduction The Serious Fraud Office (SFO) published an updated guidance on evaluating compliance programmes on November 26, 2025, solidifying a “refreshed approach” to corporate cooperation. The Guidance is particularly relevant as it outlines how “reasonable procedures” will be assessed under the new Failure to Prevent Fraud (FTPF) offence. The SFO’s updated position emphasizes demonstrable action over documentation. Key Takeaways Proof […]
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