The SFO's New Business Plan & Full Steam Ahead on Enforcement
The Serious Fraud Office (SFO) published its Business Plan 2026-27 on 16 April, marking the midway point of the agency's five-year strategy. For organisations operating in the UK, the message is clear: the SFO's foot remains firmly on the accelerator.
Nick Ephgrave QPM retired as SFO Director in April, half-way through a tenure that was defined by proactive enforcement. The SFO conducted more dawn raids in Ephgrave’s first three months of oversight than in the previous three years. Interim Director Graham McNulty, who also comes from a policing background, has been explicit that this momentum will continue. He described 2026-27 as a "pivotal year" and pledged to maintain the SFO's focus on sharper, faster casework. During a public event in April, McNulty said that the Plan demonstrated the agency’s “ambition and focus” on their priorities, “including intelligence-led investigations, innovative modern tools and effective disclosure.” He added that the SFO “are determined to increase the pace and efficiency” of their work.
The Business Plan also reinforces the direction of travel. Backed by over £8.3 million in added funding secured at the last Spending Review, the SFO will invest heavily in proactive intelligence, aiming to identify and intervene in suspected fraud, bribery and corruption earlier and more precisely. The plan also commits to deploying AI and automation tools, launching the SFO's first-ever case management system. In the Plan’s foreword, McNulty stated that he plans to “build on the firm foundations Nick leaves behind” and that the year will “bring new momentum”, with the agency using innovative skills and techniques to “strike earlier.”
On prevention, the SFO will deliver its corporate prevention programme, designed to give businesses the tools and incentives to prevent bribery and corruption, but also serving as a reminder of what the SFO expects of organisations as a baseline. Its updated corporate guidance, already refreshed last year, signals that the bar is rising.
Internationally, the SFO is projecting even greater reach. This month, it hosted the International Economic Crime Conference in collaboration with France’s Parquet National Financier (PNF) and Switzerland’s Office of the Attorney General (OAG), bringing together over 100 investigators and prosecutors from across the world. The SFO will also respond to the Financial Action Task Force inspection of the UK, a process that typically results in increased pressure on domestic enforcement activity.
For businesses, the cumulative picture is one of an agency that is better resourced, better equipped, and more internationally connected than at any point in recent years. With the Failure to Prevent Fraud offence in force, and the SFO investing explicitly in earlier intervention and proactive intelligence, the risk of businesses finding themselves in the crosshairs of an investigation is a live and growing compliance concern.