Serious Fraud Office’s New Guidance Aims to Clarify Self-Reporting Expectations and Boost Corporate Cooperation

In an interview with Anti-Corruption Report, Corporate Investigations & White Collar Defense partner Audrey Koh described the 2025 Guidance as indicative of a shift in tone under SFO Director Nick Ephgrave, noting, “it is definitely a sea change to the previous director.” She explained that Ephgrave has emphasized self-reporting and whistleblowing as central tools to increase prosecutions.

However, Koh also cautioned companies not to place too much faith in the 2025 Guidance’s assurances. “We all know how negotiations take place, and it might come to nothing,” she said. She further stressed the importance of court approval in the process, adding, “At the end of the day, it still has to be reviewed and approved by a judge, so he or she will be the final arbiter.”

Addressing the issue of prolonged investigations following most self-reports, Koh identified them as a persistent obstacle: “That is always the pain point,” she said, referencing extended timelines and high legal costs.

Despite these concerns, she acknowledged practical improvements in the self-reporting process. In the past, due to the unclear lines of communication, “some reports [were] disappearing into the ether.” Now, she explained, “Having a dedicated team, a portal and a structured way in which reports will be handled addresses the previous concerns”—calling the reform “definitely welcome.”

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