The Serious Fraud Office (SFO) has unveiled its Business Plan for 2025-26, outlining its strategy to combat serious fraud, bribery, and corruption. The Business Plan forms part of the SFO's five-year strategy launched last year.

Recent updates

The Business Plan provides a brief update on the SFO’s track record: 

• eight new investigations have been opened; 
• the first case under Nick Ephgrave’s tenure as Director has been charged (relating to the collapse of Axiom Ince); and
• five cases are listed for trial in 2026. 

Key objectives 

The key objectives in the Business Plan include the following.

• People: Launching a people strategy to ensure the SFO has a specialised and skilled workforce. 
• Digital: Delivering the SFO’s Data Driven Review project to standardise the delivery of large-scale document reviews and delivering a commercial off the shelf case management system. 
• Combatting crime: In terms of prevention, the SFO intends to deliver a crime prevention programme and launch new corporate guidance. Some of the most interesting developments look to be in intelligence and enforcement, where the SFO plans to (a) develop and maximise its cryptoasset investigation capabilities; (b) build an asset confiscation enforcement team; (c) strengthen covert surveillance capabilities; and (d) progress whistleblower incentivisation reform. 
• Proactivity as a key player in the global and domestic justice system: Working to prepare for the UK’s upcoming Financial Action Task Force inspection in 2027 and contributing to criminal justice and disclosure reform. 

Many of these issues have already received widespread publicity. The introduction of the failure to prevent fraud (FTPF) offence in September (on which we have previously commented) is likely to be the highest profile development this year. 

The SFO’s key milestones include the refreshed corporate guidance, to be updated in light of FTPF, and delivery of a new case management system. Case management and disclosure is an area in which the SFO has received criticism in the past due to shortcomings in the technology and processes it has used, which resulted in a review of many of the agency’s historic and ongoing cases. Other interesting areas to watch include discussion around the introduction of incentives for whistleblowers, as well as the development of specialist enforcement capabilities at the SFO. 

The Business Plan notes the development of partnerships with law enforcement in other jurisdictions. This follows from the recent announcement of collaboration between the SFO and its counterparts in France and Switzerland to launch an anti-bribery task force. The Business Plan also emphasises the importance of private sector relationships and cooperation in combatting economic crime. Businesses should ensure that they are aware of their obligations and have appropriate policies and procedures in place to tackle economic crime. 

We will watch with interest to see how the SFO delivers on the Business Plan.