Corporate America, be warned: the UK Serious Fraud Office has quietly removed from its Website guidance on facilitation payments, self-reporting, and corporate hospitality, as the agency reconsiders its position in dealing with these issues.

Previously, the SFO had reassured companies in published guidance that it would not prosecute companies for facilitation payments if they followed certain procedures. Nor would they be prosecuted for corporate hospitality so long as it was “reasonable and proportionate.”

The SFO further withdrew guidance that previously stated that companies could face civil, rather than criminal, penalties if they self-report corruption. The removal of the guidance on self-reporting is “not surprising,” given that the SFO has been looking to update the self-reporting guidance following enactment of the Bribery Act, stated a client alert from law firm ReedSmith.

Raymond Sweigart, a partner with law firm Pillsbury, offers this theory: “Perhaps this withdrawal is simply part of the government's plans to introduce formal deferred-prosecution agreements as a permissible tool to deal with economic crime committed by commercial organizations.”

“Nevertheless, given the uncertainty that necessarily should follow the SFO's unexplained withdrawal of guidance, anyone considering self-reporting either to the SFO or other investigative body in the U.K. or elsewhere for the moment should carefully reevaluate both that approach and its timing," Sweigart adds. “It may actually be a positive step toward cooperation between business and government in this regard, although many issues will still need further consideration and resolution.”

The guidance is currently under review. And when will that review wrap up? Stay tuned.