Rachel Warren and Charlotte Healy write for FT Adviser on how the Serious Fraud Office's latest business plan measures up against its five-year strategy

Over the past five years, the Serious Fraud Office has embarked on a significant transformation. While its 2019–22 strategy set broad ambitions around investigative capability and technology, it lacked measurable targets. This changed with the 2022–25 strategy, which introduced clear performance goals and was followed by a renewed focus under new director Nick Ephgrave in the 2024–29 strategy.

Since Ephgrave's retirement halfway through his five-year term, the SFO's interim director Graham McNulty has released an updated 2026-27 business plan for the organisation. Published in April 2026, this confirmed that the SFO's strategic direction has survived the change in leadership, with a commitment to maintain focus on “intelligence-led investigations, innovative, modern tools and effective disclosure”. 

Taken together, the SFO’s business plans indicate that its transformation is now firmly under way, with new systems embedded, prevention initiatives rolled out, and international engagement beginning to deliver tangible results.

Rachel Warren, Partner and Charlotte Healy, Associate in our Dispute Resolution team, write in FT Adviser:

The legislative landscape has responded; through ECCTA, expanded pre-investigative powers, overseas production orders and new self-reporting incentives. The SFO itself has also responded in a shift from prosecutor and investigator to a body that also seeks to shape its operating environment, build global partnerships, and prevent financial crime from occurring.

Whether the ambition matches the reality will be tested as the SFO moves through the second half of its five-year strategy, but the direction of travel is clear.

Read the full article in FT Adviser here.