In 2025, the SFO issued guidance outlining its expectations for companies seeking a DPA. Until recently, that guidance was merely theoretical, with DPAs thin on the ground. However, a recent settlement with Ultra Electronics Holdings Ltd, a British defense and security company, indicates that the U.K. enforcer is back in the game. This first installment in a two-part series on the case examines the company’s self-report and cooperation in the SFO’s investigation. The second part will analyze how Ultra Electronics cleaned up its compliance program and ultimately paid limited penalties, partially due to its failure to win business through paying bribes. See our two-part series on the 2026 U.K. enforcement outlook: “Compliance Evaluation Guidance” (Feb. 11, 2026), and “A Whole-Government Strategy to Fight Corruption” (Feb. 25, 2026).