Jurisdiction(s):
United Kingdom

SFO's enforcement reset: failure to prevent fraud, expanded identification doctrine and revived DPAs intensify corporate liability and self-reporting decisions

Published on: 04 November 2025

Published by a Law360 reporter

Legal News

Article summary

Two years later, the outlook for the SFO appears markedly altered. Over the past quarter, it has secured a significant new charging avenue via the failure to prevent fraud offence, recovered £1.1m through its inaugural unexplained wealth order (UWO), and brought charges against six people arising from a pension fraud probe. Against that backdrop, we reflect on the themes that have shaped Ephgrave’s tenure leading the SFO so far, and consider what may follow.

Kicking down new doors and closing old ones

In February 2024, delivering his first public address as director, Ephgrave set out a drive to accelerate casework and make the SFO bolder, more pragmatic, more proactive. His opening months featured a spike in dawn raids, and he said the team had gone through more front doors in three months than in the previous three years. Eighteen months later, that pace endures. Since his arrival, the SFO has announced ten fresh investigations and a host of charges, many after strikingly brief investigative phases, a sharp departure from the very lengthy cases that had become routine within the agency. The focus on tempo, pragmatism and decisive charging has been a defining feature of his leadership, and looks set to continue apace...

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