On 24 April 2025, the Serious Fraud Office (SFO) released updated guidance aimed at helping businesses—including small law firms—understand how to raise concerns about suspected fraud or corruption and how to engage with the SFO when wrongdoing is identified.
Why This Matters for Small Firms
Small law firms may find themselves advising corporate clients or even facing internal concerns about financial misconduct. The SFO’s guidance offers a clear pathway for firms to self-report and potentially avoid prosecution through a Deferred Prosecution Agreement (DPA).
Key Takeaways for Small Firms
- Self-reporting is encouraged: Firms that report suspected misconduct early and cooperate fully may be offered a DPA instead of facing criminal charges.
- Quick response: The SFO will respond to a self-report within 48 hours.
- Timely decisions: A decision on whether to open an investigation will be made within six months.
- Efficient resolution: DPA negotiations are expected to conclude within six months of invitation.
- No need for a full internal investigation before reporting—come forward as soon as direct evidence of misconduct is discovered.
Even Without a Self-Report…
Small firms that demonstrate exemplary cooperation during an investigation may still be invited to DPA negotiations, even if they didn’t initiate a self-report.
Practical Steps for Small Law Firms
- Establish internal procedures for identifying and escalating suspicions of fraud or corruption.
- Ensure your nominated officer is trained and ready to assess whether a Suspicious Activity Report (SAR) is required.
- Familiarise yourself with the DAML exemption provisions under the Economic Crime and Corporate Transparency Act 2023.
Read the full SFO Corporate Guidance here.