SFO 5-year strategic plan unveiled

We commented on the first public speech of Nick Ephgrave, the new director of the Serious Fraud Office (SFO), delivered in February 2024.

On 18 April 2024, the SFO published its 5-year strategic plan, setting out its core purpose and strategic priorities.

The plan follows Mr Ephgrave’s stated intentions for the SFO to be bolder, pragmatic and more proactive and has at its focus an increased use of technologies, including the use of AI, to assist its focus on the prevention of fraud and corruption.

In his inaugural speech, Mr Ephgrave referred to improving efficiencies within the SFO and working collaboratively with other law enforcement agencies which is played out in the Plan.

The mission of the SFO is stated in the Plan to be “We [the SFO] fight complex financial crime, deliver justice for victims and protect the UK’s reputation as a safe place to do business”. Their vision is that by 2029 “we [the SFO] specialise, collaborate, and innovate to lead the fight against serious fraud, bribery and corruption.”

The Plan has been summarised into the following outcomes:

• We have a highly specialised, engaged and skilled workforce;
• We are ready and able to harness the technology and tools of an every changing world;
• We combat crime effectively through intelligence, enforcement and prevention; and
• We are a proactive, authoritative player in the global and domestic justice system.

The delivery of the Plan is going to be tracked against four key indicators:

• Justice outcomes;
• Operational delivery;
• Organisational strength and resilience; and
• Finance.

The plan also wants to explore incentivisation options for whistle blowers, working with partners in the UK and abroad to find ways to encourage more corporate referrals.

The SFO have pledged they will carry out a formal review of the strategy in 2026/27 to ensure it remains relevant and meaningful as they recognise the world in which they operate is ever-changing and focus may change, and will possibly need to change, accordingly. 

The SFO also recognises that as a result its cases are becoming more complex and thus taking longer to resolve or bring to a successful conclusion.

The Plan, and indeed Mr Ephgrave’s introduction to it, places an emphasis on the workforce of the SFO; there is a recognition that in order to be able to deliver the Outcomes proposed by the Plan, the SFO will need to attract and retain a range of professionals, at their peak, to ensure the SFO is at the forefront of emerging technology and seeking to be one step ahead of the criminals it strives to expose.

The Plan proposes that the SFO will utilise innovative new tools and focus on the use of AI for more mechanical and administrative tasks, with a clear aim of freeing up individuals for those tasks that require expert human impact!

The SFO also recognises that whilst being UK based, they are part of a much bigger global picture and accordingly that collaboration across difference agencies and jurisdictions is critical to the successful delivery of the Plan. There is a stated aim to make collaboration as easy as possible for all relevant partners and stakeholders with an intention to build strong trusting relationships across multiple jurisdictions.

Comment

Colette Kelly, Partner in Irwin Mitchell’s Regulatory and Compliance Group, comments on the SFO Plan:

“The Plan is bold and ambitious however is thin on the detail of the options to be explored for whistleblower incentivisation. The outcomes and deliverables identified need to be properly funded and resourced”.