Transparency International and Spotlight on Corruption sent the Director of the SFO a letter on 13 February to urge the SFO to carry out - in conjunction with the AG's office and the CPS - a review of the effectiveness of the DPA regime in doing what it was principally designed to do -  to encourage better corporate behaviour, a key feature of which is the self-reporting of wrongdoing.  Among other things, the concern has been raised that the Airbus DPA, in explicitly moving away from the "bright line" between self-reporting and cooperation, may lead to corporates being disincentivised to bring matters to the attention of the authorities, knowing that if they cooperate to the fullest extent thereafter, a DPA is a likely outcome.  The letter has a point - and rightly focuses on the distinction that US authorities draw between self-reporting (which deserves the fullest credit) and cooperation (which deserves less) suggesting the UK should follow suit. However, a 25% discount for cooperation, however exemplary, where there is no self-report, may not provide sufficient incentive for corporates to settle criminal charges, particularly as a discount of one-third would apply if they pleaded guilty at the earliest opportunity.