DPA Financial Quantification: How Forensic Accountants Calculate Disgorgement

A DPA financial settlement comprises three elements: disgorgement of profits or benefits from misconduct, a financial penalty (typically equal to or greater than disgorgement), and prosecution costs. The disgorgement figure is the foundation around which the entire negotiation revolves.

Disgorgement represents the net benefit the organisation obtained from the misconduct. Forensic accountants trace financial benefit through organisational accounts, identifying profits made or losses avoided as a direct result of the fraudulent or corrupt conduct, netting legitimate costs from tainted activity.

Self-reporting under 2025 SFO guidance explicitly leads to DPA invitation where full cooperation is provided. Forensic accountants quantify misconduct scope before disclosure, enabling informed negotiation. Penalty multiplication above disgorgement reflects punitive and deterrent objectives.

HMRC has also used DPAs in tax cases. The forensic methodology parallels SFO DPAs: establish benefit, model penalty scenarios, and support ongoing negotiation with updated financial analysis as disclosure progresses.