Dan Hudson comments in Law360 on new SFO self-reporting guidance

28 April 2025

Seladore Legal’s Dan Hudson has been quoted in Law360 on the Serious Fraud Office’s new approach to corporate self-reporting.

The SFO has announced that companies disclosing suspected wrongdoing will be spared prosecution except in “exceptional” cases, backed by strict timetables for agency responses.

The new guidance is intended to encourage earlier engagement, self-reporting, and greater use of Deferred Prosecution Agreements, though questions remain as to whether self-reporting will always be the best course – particularly given wider changes to corporate criminal liability and new incentives proposed for whistleblowers.

Dan commented: “The upcoming extensions of corporate criminal liability adds to the tension. Companies will be more incentivized to throw complicit managers and employees at the SFO’s mercy before non-complicit – but perhaps disaffected – individuals with knowledge blow the whistle.”

This is particularly so if the SFO gets its way and is permitted to offer rewards to whistleblowers, which could see corporates and their staff in a race to the SFO’s door.

In addition, the new Guidance places emphasis on genuine self-reporting or exemplary co-operation and its warning that investigatory ‘forum-shopping’ will be viewed as uncooperative.

When viewed together with the US Administration’s significant ‘dialling down’ of enforcement activity (particularly in the foreign bribery space) and the recent announcement of charges by the SFO against insurer UIBL for failing to prevent overseas bribery – which could see a rare trial focussing on the question of what are “adequate procedures” – these developments all suggest that the SFO is doing its utmost to increase its enforcement activity (including in relation to overseas conduct).

READ MORE

Related Articles


Seladore Legal announces the arrival of David Gilmore as Partner

Seladore Legal is pleased to announce that David Gilmore has joined the firm as a Partner, further strengthening its international arbitration and cross-border disputes offering across London and Asia.

Read More Seladore Legal announces the arrival of David Gilmore as Partner
05 January 2026
Seladore contributes to GIR Market Review: Privilege 2025 

In this year’s edition of GIR Market Review: Privilege 2025 for Global Investigations Review, Dan Hudson, Kevin Kilgour and Luke Taylor explore how legal privilege is adapting to new technologies and the evolving landscape of investigations.

Read More Seladore contributes to GIR Market Review: Privilege 2025 
02 December 2025
Seladore acts in successful Privy Council case on “just and equitable” winding up

Seladore Legal has acted for the successful Respondent in a Privy Council appeal upholding the winding-up of a Cayman exempted limited partnership on the just and equitable ground, clarifying the scope of the jurisdiction beyond traditional “quasi-partnership” cases.

Read More Seladore acts in successful Privy Council case on “just and equitable” winding up
27 November 2025

Subscribe to Our Newsletter

Get the latest developments from Seladore Legal straight to your inbox.

First Name(Required)
Name(Required)
Legal Terms(Required)