The honey moon is over.

The SFO have this morning published their position in relation to facilitation payments, corporate hospitality and self reporting.  The links to the new policies are here.  The revised position replaces previous guidance issued by the SFO under the then Director Richard Alderman.

For business expenditure click here.

For facilitation payments click here.

For self reporting click here.

Opinion

The revised guidance is a model of clarity.  

The new Director has previously made his position clear namely that the SFO is not there to provide guidance and those seeking it should liaise with their advisers.

Reading between the lines, the good news is that the SFO have confirmed again that corporates should not be nervous about legitimate corporate hospitality.  We agree.

On facilitation payments, the SFO position now simply restates the UK legal position and the various tests the SFO will use when weighing prosecution.

The big news is likely to be in relation to Self Reporting.  The new statement on Self Reporting is brief noting that it will be a factor taken into account when weighing up a decision to prosecute.  There is no expressed preference (as there was) in favour of civil settlement.

The big question? Will corporates feel more or less inclined to Self Report today?