What Compliance Leaders Must Know About the Recent SFO Guidance and ECCTA Implementation
The UK is ushering in a new era of corporate crime enforcement - one defined by transparency, speed, and serious consequences for inaction.
With the Serious Fraud Office (SFO) releasing updated self-reporting guidance together with the failure to prevent fraud provision in the Economic Crime and Corporate Transparency Act (ECCTA) set to take effect in September 2025, compliance leaders are facing a rapidly shifting landscape.
These changes aren’t just procedural - they reflect a broader shift in enforcement philosophy. Regulators are signaling clearly if you find misconduct, tell us first, and you’ll be treated more favourably than if we find it for you.
This moment demands more than reactive compliance. It calls for strategic self-reporting frameworks, cross-border risk coordination, and technology-enabled prevention - all built into the fabric of your compliance program.
A New Era of Self-Reporting: What the SFO Guidance Means
The UK SFO’s new external guidance on corporate cooperation and enforcement outlines clear parameters for:
- When and how organisations should self-report misconduct
- What constitutes meaningful cooperation
- How to obtain a Deferred Prosecution Agreement (DPA)
Key feature: There is now a presumption of a DPA for companies that voluntarily disclose misconduct - unless extraordinary circumstances suggest otherwise.
How it works:
- Companies can self-report via a new secure online portal, which guarantees acknowledgment within 48 hours.
- The SFO commits to structured timelines for decision-making.
- The guidance aligns with the DPA Code of Practice under the 2013 Crimes and Courts Act but makes expectations more operational and transparent.
What it signals: The SFO is leaning in, making it clear that early, voluntary engagement isn’t just encouraged, it’s the surest path to a more favourable outcome. Wait to be discovered, and you lose that advantage.
The ECCTA: A Broader Risk Net for Global Businesses
Coming into force on September 1, 2025, the Economic Crime and Corporate Transparency Act introduces a sweeping new corporate offense: failure to prevent fraud.
It applies to any company with UK exposure and especially targets fraud that benefits the business itself. This is broader than previous offenses like bribery and will affect functions such as finance, accounting, sales, and operations.
Even internal misconduct - like inflating revenue projections to impress investors - can now trigger corporate liability under ECCTA. It’s a clear warning for any business with UK exposure: the scope of risk has expanded, and the margin for error has narrowed.
Strategic Integration: How ECCTA and the SFO Guidance Work Together
These two regulatory moves aren’t isolated, they’re designed to work in tandem. ECCTA mandates reasonable prevention procedures. The SFO guidance tells you what happens if those procedures fail, and how to respond smartly.
Key takeaway:
Companies should prepare for self-reporting as part of their risk and compliance strategy, not just an emergency option.
The SFO even cautions against forum shopping - selecting a more “favourable” jurisdiction for disclosure. Cross-border coordination and early engagement are now core components of what regulators consider cooperative behavior.
How to Operationalise Compliance: Embedding ECCTA and SFO Expectations into Your Tech Stack
To meet the ECCTA’s fraud prevention requirements, and act on SFO guidance quickly when issues arise, your compliance technology needs to support real-time visibility, structured workflows, and evidence-based decisions.
1. Centralise and Monitor Beneficial Ownership Data
Why it matters: ECCTA requires entities to disclose and keep up-to-date records on Persons with Significant Control (PSCs).
Technology considerations:
- Leverage your third-party due diligence platform to track, verify, and update beneficial ownership (UBO) information.
- Integrate with external data providers (like GAN Integrity Due Diligence, Sayari, Dun & Bradstreet) to screen and refresh PSC data continuously.
- Automate reminders and workflows for re-verification and updates.
2. Enhance Third-Party Due Diligence and Risk Screening
Why it matters: ECCTA elevates expectations for detecting financial crime, especially in high-risk sectors or jurisdictions.
Technology considerations:
- Configure your TPRM or compliance platform to apply risk-based onboarding and enhanced due diligence (EDD) rules for high-risk third parties.
- Use workflows that automatically escalate third parties for additional review when red flags appear in updated Companies House filings or third-party risk data - such as a new beneficial owner, director disqualification, or an adverse media hit.
- Use AI-enabled tools to detect hidden ownership structures or red flags in corporate filings.
- Broader global coverage through multilingual and multi-jurisdiction media ensure you are alerted to region-specific risks that keyword lists might miss.
- Risk scoring and confidence-baked ranking prioritize the most relevant adverse media items first, minimising manual triage workload and simplified analyst triage.
3. Automate Reporting and Record-Keeping
Why it matters: ECCTA places greater emphasis on accurate, timely, and auditable disclosures.
Technology considerations:
- Use your platform to log all due diligence actions, updates to PSC data, and approvals, creating a defensible audit trail.
- Automate generation of reports for internal stakeholders or regulators.
- Tag records with ECCTA-relevant metadata (e.g., filing deadlines, PSC types, ID verification status).
4. Embed ECCTA Triggers into Your Policy & Risk Controls
Why it matters: You’ll need to respond to ECCTA-related changes (e.g., discrepancies in Company House filings) as part of your overall compliance framework.
Technology considerations:
- Link policy attestations and training campaigns to ECCTA requirements using your compliance training platform.
- Update risk assessment templates to include ECCTA exposure questions for new entities or M&A activities.
- Build dynamic workflows that adjust onboarding or monitoring steps based on jurisdictional ECCTA relevance.
5. Ensure Gifts and Entertainment Compliance
Why it matters: Under the ECCTA’s “failure to prevent fraud” offense, any internal misconduct that benefits the business can create corporate liability - this will include misuse of G&E to:
- Influence procurement or sales decisions
- Falsely inflate business performance
- Mask bribery or kickback schemes
The ECCTA includes a defense if the company can show “reasonable prevention procedures.” A strong G&E program helps demonstrate this by:
- Setting clear thresholds and approval workflows
- Tracking and auditing all G&E activity
These controls signal that the company has thought through how misconduct could occur, and actively works to prevent it.
Technology considerations: Modern compliance platforms should enable you to:
- Flag G&E submissions based on risk thresholds
- Auto-route high-risk entries for additional review
- Map G&E activity to third-party profiles
- Generate audit trails for all approvals and rejections
This automation is key to spotting patterns, showing enforcement-readiness, and avoiding manual oversight.
Things to avoid in technology: Avoid platforms where these red flags are present:
- Siloed systems lead to blind spots in fraud and reporting
- Manual tracking systems are inefficient, lack audibility and have a high error risk
- Non-compliant vendors could expose you to various regulatory and reputational liabilities
6. Training and Whistleblowing Compliance
Why it matters: Training plays a vital role in ECCTA compliance
- Staff and associated individuals must be well-versed in fraud prevention procedures and whistleblowing policies.
- Training should be tailored to address the specific risks identified within the organisation.
- Existing training frameworks can be updated to cover the identification, prevention, and reporting of fraud.
- Consider extending training to third parties or encourage them to implement their own relevant programs.
Also of consideration: Whistleblowing forms a core element
- An effective whistleblowing policy is key for identifying and preventing economic crime while promoting a culture of integrity, transparency, and responsibility.
- A strong whistleblowing framework may also help reduce penalties in the event of an investigation.
- The SFO is expected to release guidance and incentives for whistleblowers, possibly introducing financial rewards similar to the US approach. This development could notably influence how and when organizations opt to self-report concerns.
7. Enable Cross-Functional Collaboration
Why it matters: ECCTA compliance touches legal, finance, procurement, and compliance.
Technology considerations:
- Ensure your platform supports multi-role collaboration (e.g., assigning tasks to legal for PSC review or to procurement for third-party screening).
- Use dashboards and visualisations to share ECCTA-related insights across departments.
Don’t Forget: Keep an Eye on Phase-In Timelines
Some ECCTA requirements (like ID verification for directors and PSCs) are still being phased in. Make sure your tech stack can adapt to evolving guidance and integrate updates without disruption.
Time Is Short. Strategy Matters.
The new SFO guidance and ECCTA are part of a broader global trend, mirroring shifts in the US DOJ and new anti-corruption coalitions between the UK, France, and Switzerland. This is part of a coordinated effort among regulators to make it easier, and more attractive, for companies to engage early and do the right thing.
But the window for preparation is closing. The organisations that succeed will be those that treat compliance as a strategic function, leverage technology, and partner with regulators rather than gamble on silence.
Want to learn more about how this could affect your programs? See us in action today.