header-logo header-logo

22 May 2026 / Cameron Brown KC , Sam Smart
Issue: 8162 / Categories: Features , Criminal , Practice areas , Jurisdiction
printer mail-detail

The new enforcement playbook?

250393
© Getty images
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

If you are not a subscriber, subscribe now to read this content
If you are already a subscriber sign in
...or Register for two weeks' free access to subscriber content

MOVERS & SHAKERS

NLJ Career Profile: Maryam Syed KC, Church Court Chambers

NLJ Career Profile: Maryam Syed KC, Church Court Chambers

From childhood dreams of the Bar to some of the country's most challenging cases, Maryam Syed KC explains why she has never stopped standing up for others

DAC Beachcroft—Richard Breavington, Rachel Ford & Daniel Guilfoyle

DAC Beachcroft—Richard Breavington, Rachel Ford & Daniel Guilfoyle

DAC Beachcroft significantly expands Cyber team, hiring three Cyber partners

Browne Jacobson—Professor Clive Kay

Browne Jacobson—Professor Clive Kay

Browne Jacobson appoints senior healthcare leader Professor Clive Kay as strategic adviser

NEWS
CEDR has announced the death of its Founder President and first Chief Executive, Dr Karl Mackie CBE
Consumers will receive their Merricks v Mastercard compensation in the first half of next year, class representative and former Financial Ombudsman Walter Merricks has said
A law firm was not entitled to payment for jointly administering an estate as there was no charging clause in the will, the High Court Senior Courts Costs Office has ruled
The so-called ‘Dieselgate’ quantum trial will go ahead against Mercedes, after the High Court rejected an attempt by car owners to delay the proceedings
The Ministry of Defence (MoD) must pay the bulk of the legal costs in the military deafness litigation, the High Court has held
back-to-top-scroll