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Caroline Greenwell, Abigail Rushton and Bella Henry write for Solicitors Journal on the latest Business Plan from the Serious Fraud Office

The UK's Serious Fraud Office (SFO) has unveiled its 2025-2026 Business Plan, marking the first under new Director Nick Ephgrave. This plan is a pivotal component of Ephgrave's five-year strategy, aligning with ambitions outlined in the SFO's Annual Report from July 2024. The plan highlights key developments, including eight new investigations, the first charge under Ephgrave's leadership related to Axiom Ince, and five cases slated for trial in 2026.

In an article for Solicitors Journal, Caroline Greenwell, Partner, Abigail Rushton, Senior Associate, and Bella Henry, Associate, unpick the latest Business Plan from the Serious Fraud Office.

A significant feature of the Business Plan is the new "failure to prevent fraud" offence under the Economic Crime and Corporate Transparency Act 2023, effective from September 2025. 

International cooperation is another focus, with the SFO forming an anti-corruption alliance with France and Switzerland. Ephgrave underscores the importance of global partnerships in tackling cross-border economic crime.

The SFO has also released guidance on corporate cooperation, encouraging self-reporting and promising Deferred Prosecution Agreements (DPAs) for compliant organisations. This guidance aims to enhance transparency and efficiency, addressing previous criticisms of delays in case progression.

Moreover, the SFO is exploring whistleblower incentivisation, potentially offering payments from corporate settlements to those providing evidence of wrongdoing. This approach, akin to US practices, could elevate corporate compliance standards by motivating insiders to report fraud.

While Ephgrave's tenure is still in its early stages, the Business Plan reflects promising strides towards enhancing the SFO's efficiency and international standing. Organisations must stay vigilant, adapting to new guidance and preparing for the forthcoming "failure to prevent fraud" offence. The potential whistleblower reforms could further intensify SFO activity, necessitating additional funding to support increased investigatory demands.

Read the full piece in Solicitors Journal here.

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