The Serious Fraud Office ("SFO") has released its Business Plan for 2025-26, outlining significant changes and strategic initiatives aimed at combatting serious fraud, bribery, and corruption. The Plan is framed by the SFO chief, Nick Ephgrave's comments reported on 14 April 2025 questioning why the SFO is not "hungrier" and "more aggressive", suggesting that these changes are not mere lip-service.
This alert highlights the key changes, their implications, and what your business needs to pay attention to.
- New Case Management System. The SFO will implement a new case management system to streamline casework. This system is expected to enhance the efficiency and effectiveness of investigations, potentially leading to quicker resolutions and more robust prosecutions. Companies should take steps now to ensure compliance and legal teams are prepared for potentially faster investigative processes and increased scrutiny.
- Failure to Prevent Fraud Offence. The new Failure to Prevent Fraud offence will become effective in September 2025. See our previous publications here and here, explaining the scope and application of the offence. In summary, the offence widens the scope of prosecutions, holding companies accountable for failing to prevent fraudulent activities. The offence will apply to any company which fails to show it had in place reasonable fraud prevention procedures such that an employee (i) committed fraud as defined by UK law or (ii) defrauded victims based in the UK, regardless of whether the company or its employees are domiciled in the UK. Companies are advised to review and strengthen internal controls and compliance programmes to mitigate the risk of falling foul of this new legislation.
- Whistleblower Incentivisation Reform. The SFO is pushing for reforms to incentivise whistleblowers. Such enhanced whistleblower protections and incentives could lead to an increase in reports of fraudulent activities. See our previous publication discussing this in more detail here. Companies should develop or update whistleblower policies to ensure they are robust and encourage internal reporting.
- Cryptoasset Investigation Capabilities. The SFO intends to develop new capabilities for investigating cryptoassets. As the use of cryptoassets grows, so does the potential for their misuse in fraudulent activities.The SFO's enhanced capabilities will allow for more effective tracking and prosecution of such crimes. Companies that deal with cryptoassets must take steps to ensure compliance with relevant regulations and be prepared for increased scrutiny.
- Prevention Programme. The SFO will launch a new prevention programme to build relationships with the private sector. This initiative aims to foster collaboration between the SFO and businesses to prevent economic crimes. Where applicable, companies are advised to engage with the SFO's prevention programme to stay ahead of regulatory expectations and contribute to a safer business environment.
The SFO's Business Plan for 2025-26 sets out impressive ambitions for the coming year. The Plan has been published against a backdrop of increased cooperation with prosecuting authorities in other jurisdictions too, making international collaboration another key area of focus for the SFO – see our previous client alert here for more details.
Businesses must stay informed and proactive in adapting to these changes to ensure compliance and mitigate risks. The Mayer Brown team is closely monitoring these developments and their potential implications, and is fully equipped to advise companies in all sectors.
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