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22 May 2026 / Cameron Brown KC , Sam Smart
Issue: 8162 / Categories: Features , Criminal , Practice areas , Jurisdiction
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The new enforcement playbook?

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Cameron Brown KC & Sam Smart assess the evolving landscape of deferred prosecution agreements
  • The UK’s deferred prosecution agreement regime is evolving, with revised SFO guidance and greater CPS involvement increasing opportunities for corporates that genuinely cooperate.
  • Recent cases emphasise the importance of corporate reform, strong compliance and self-reporting, while prosecutions of individuals remain challenging.

The UK’s deferred prosecution agreement (DPA) regime is potentially entering a new phase for a number of reasons. First, the changing of the guard at the Serious Fraud Office (SFO), with interim director Graham McNulty QPM appointed after the departure of Nicholas Ephgrave QPM, who steadied the ship following the departure of Lisa Osofsky. Second, the Crown Prosecution Service (CPS) in 2023 entered the DPA arena in a substantive way, concluding the second largest ever DPA at £615m. Third, a maturing body of case law and guidance has reshaped the requirements of corporate cooperation and arguably makes it more likely that corporates will be invited into a DPA.

DPAs to date

While

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NEWS
The government is considering introducing a Serious Fraud Office (SFO) financial incentives scheme for individuals who report economic crime
Defendants will attend their first court hearing virtually via a secure link from a police custody suite, the Ministry of Justice (MoJ) has confirmed in its response to Lord Leveson’s independent review of the criminal courts
The Law Commission has proposed a major overhaul of product liability laws to bring them in line with the digital age and era of artificial intelligence (AI)
The Sentencing Council is consulting on three new and three revised guidelines for ‘Bladed article and offensive weapon etc offences’
The Ministry of Justice has laid secondary legislation to allow, for the first time, proceedings in the Administrative Court, a part of the King’s Bench Division in the High Court, and sentencing remarks by the Chief Magistrate to be broadcast
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