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Have you ever wondered what happens in those critical moments after discovering potential fraud within your organization? The clock is ticking, stakeholders are concerned, and the path forward seems unclear. Today, that path just became a little clearer.

Today marks a significant shift in corporate compliance expectations as the Serious Fraud Office (SFO) released its new Corporate Guidance. As someone who's navigated these waters with clients for years, I can tell you this represents an important development in how potential corporate fraud cases may be handled.

The 48-Hour Promise

The most notable element of this guidance? The SFO has committed to contacting self-reporting corporates within just 48 business hours of initial contact. For those navigating the process of submitting a self-report, this represents a clear commitment to timely communication and engagement.

The Self-Report Decision: A Timeline That Makes Sense

The guidance recognizes something I've seen firsthand—the decision to self-report is complex and requires careful consideration. While emphasizing prompt reporting, the SFO acknowledges that:

But there's a critical balance here. The guidance makes clear that if there's direct evidence of corporate offending, they expect a report "soon after learning of that evidence." Only when the situation is "less clear-cut" should further investigation occur before reporting.

From Self-Report to Resolution: A Clearer Path

For the first time, we're seeing concrete timelines for the entire process:

• Initial contact within 48 business hours

• Decision on opening an investigation within 6 months

• DPA negotiations concluded within 6 months of the invitation

These benchmarks represent a significant commitment to efficiency that should provide greater certainty for businesses navigating potential fraud issues.

What This Means For You

If you're responsible for compliance or leadership in your organization, this guidance offers three key takeaways:

Documentation matters more than ever. The moment suspicions arise, document your decision-making process and investigation timeline. This will be crucial if you need to demonstrate that reporting occurred within "a reasonable time."

Cooperation goes beyond reporting. The guidance provides specific examples of "exemplary cooperation" that could lead to DPA negotiations even without self-reporting. These examples offer a practical roadmap for organizations dealing with investigations.

The cost of delay has increased. With the SFO explicitly stating that only in "exceptional cases" will a prompt self-report and full cooperation result in prosecution rather than a DPA, the stakes for delaying action have never been higher.

What's Next?

The guidance sends a clear message: the SFO is streamlining its approach and rewarding genuine cooperation. Organizations that embrace these principles will find themselves in a stronger position when facing potential fraud issues.

Have you reviewed your fraud response protocols lately? Now is the perfect time to assess whether your procedures align with these new expectations. Would your organization be prepared to make decisions and gather information within the timelines the SFO now expects?

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