Guralp v SFO—a narrow squeak?

The Guralp case has given the Serious Fraud Office a welcome boost, writes Jonathan Fisher KC, but lessons can still be learned

The ruling in Guralp allows the Serious Fraud Office (SFO) to take enforcement action after a key term of a deferred prosecution agreement (DPA) had been breached by a defendant company.
It is essential that terms of a DPA must be simply stated. And the SFO would be well advised to improve its arrangements for diarising important dates and allowing a margin around them.
The SFO may also reflect on whether a DPA ought to have been made in a case where a company is unable to pay a fine and legal costs.

Last month’s High Court ruling in Guralp Systems Ltd v Director of the Serious Fraud Office [2026] EWHC 37 (Admin) gives a much-needed boost to the fortunes of the Serious Fraud Office (SFO), recently battered by the loss of R v Hayes; R v Palombo [2025] UKSC 29 in

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Guralp v SFO—a narrow squeak?

The Guralp case has given the Serious Fraud Office a welcome boost, writes Jonathan Fisher KC, but lessons can still be learned

The ruling in Guralp allows the Serious Fraud Office (SFO) to take enforcement action after a key term of a deferred prosecution agreement (DPA) had been breached by a defendant company.
It is essential that terms of a DPA must be simply stated. And the SFO would be well advised to improve its arrangements for diarising important dates and allowing a margin around them.
The SFO may also reflect on whether a DPA ought to have been made in a case where a company is unable to pay a fine and legal costs.

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Guralp v SFO—a narrow squeak?

MOVERS & SHAKERS

Kingsley Napley—Kelly Greig & Abbie West-Kelsey

Dawson Cornwell—Russell Bywater

Forbes Solicitors—Katy Parkinson & Paul Hatton