Following a reworking of policies in relation to the United Kingdom’s Bribery Act, the country’s Serious Fraud Office (“SFO”), which handles offenses such as corporate and investment fraud, announced that companies that self-report illegal activity will not necessarily be shielded from prosecution.  Press Release, Serious Fraud Office, Revised policies on facilitation payment, business expenditure and Corporate Self-Reporting (Oct. 9, 2012).  According to the SFO, the decision of whether to go after a company’s wrongdoing after it self-reports potential offenses will be made based on the Full Code Test in the prosecutorial code and relevant joint prosecution guidance from the SFO and the Crown Prosecution Service, with no assurance that a company will avoid prosecution just because it self-reported.  According to the SFO’s revised guidance, if there is a realistic chance of conviction, the SFO will prosecute the action if it is considered to be in the public interest. For a company’s self-report to be taken into account as a public interest factor weighing against prosecution, it has to be part of a “genuinely proactive approach” adopted by top management after the illicit conduct was brought to their notice.  The agency further stated that in instances in which it does not prosecute a self-reporting company, it still reserves the right to bring legal actions over any unreported violations of law and to share information on the reported violation to other bodies, such as foreign police services.