New UK SFO Guidance On Evaluating Corporate Compliance Programmes

On 26 November 2025, the UK Serious Fraud Office ("SFO") published an updated version of its Guidance on Evaluating a Corporate Compliance Programme (the "Guidance").¹ The Guidance expands on previously issued guidance to reflect the new failure to prevent fraud offence under section 199 of the Economic Crime and Corporate Transparency Act 2023, which came into force on 1 September 2025.

For companies, the importance of having an effective compliance programme cannot be overstated; an ineffective compliance programme can mean not only prosecution and financial penalties but also huge reputational damage. As the Guidance stresses, the effectiveness of a compliance programme will be considered by the SFO at every stage of the investigation and enforcement process. The SFO has also repeatedly asserted its intention to prosecute the new failure to prevent fraud offence,² signalling a heightened enforcement risk for companies.