The guidelines contain the different concepts that can be proposed in an SFO DPA: large-scale data collection (ideally accompanied by a full waiver of privileges) for self-reporting purposes; implementation of a robust corporate compliance program; facilitate monitoring; and the payment of a significant fine, including the deposit of profits. Finally, the guidance confirms a trend observed in recent years: a company reorganization can help a company if it claims that it has opened a new page. Such a reorganisation can also help companies avoid an exclusion due to the alleged fault, as they can argue that the infringement is limited to a fraudulent entity. Recent DPAs have registered the government`s agreement that restructured companies can continue to bid for public contracts. A DPA is an agreed judicial agreement between a company and a prosecutor that allows for the stay of proceedings for a specified period of time, provided that the organization meets certain pre-established criteria. In order to enter into a CCA, a company must admit the faults committed; pay a fine; and agree with the conditions imposed by the prosecutor. SFO has been criticized for its use of DPAs. In particular, many argued that the SFO has pursued high-level comparisons with large companies, while it has failed to obtain convictions for those involved in the offensive behavior. . . .