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Deferred Prosecution Agreements

Posted on 10 December 2024

The SFO has not entered into any deferred prosecution agreements during 2024. However, the end of 2023 did see the Crown Prosecution Service enter into its first ever deferred prosecution agreement ("DPA"), with global online sports betting and gaming business Entain plc ("Entain"). 

In November 2019 Entain disclosed that its subsidiary Entain Holdings (UK) Limited had received a production order from Her Majesty's Revenue and Customs (HMRC) requiring it to provide information on the Group’s former Turkish-facing online betting and gaming business, which it held from 2011 until it was sold in 2017. HMRC's investigation was initially focused on third party suppliers connected to the processing of payments for online betting and gaming in Turkey.  

In July 2020, Entain announced that HMRC had widened its investigation and was now investigating the commission of potential offences by entities within the Entain group.  

On 5 December 2023 it was announced that Entain had entered into a DPA with the CPS in relation to four instances of failure to prevent bribery contrary to section 7 of the Bribery Act 2010. Under the terms of the DPA which is in force for four years, Entain agreed to pay a financial penalty and disgorgement of profit totalling £585 million; HMRC and the CPS’s costs of £10 million and a charitable payment of £20 million.  

Some of the factors that appear to have persuaded the Court to approve the DPA include the sweeping changes that Entain had made to its compliance procedures, its commitment to promoting transparent and open gambling operations, and improvements to its corporate governance. 

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