Proper, in-depth analysis will take a little time. But we can't resist a few quick-takes on some of the more interesting points now. In no particular order, these are:
- The SFO begins with the valid point that what qualifies as "co-operation" in each case will turn on the specific facts. Quite right. Excitable commentary from lawyers and others on every new guideline, good-practice standard or similar sub-regulatory material can sometimes ignore this fundamental precept. Individual results may differ. It is refreshing to see the SFO state this early and clearly.
- The Guidance explains the broad scope of expected co-operation by corporate bodies, at some length. The principles include providing all relevant information in a timely way and not seeking to delay or mislead the SFO, including by omission of information. Most of this reflects good practice in this sphere and the sort of thing the US and other authorities have been saying for some time.