With the Serious Fraud Office having published its 2026-27 business plan, Syed Rahman of Rahman Ravelli looks at the goals the agency has set itself.
Failing to plan is planning to fail, as the old saying goes. And that is an accusation that cannot be levelled at the Serious Fraud Office (SFO), which has never been short of a plan or two.
The SFO has published its business plan for 2026-27 which, as keen observers of plans will know, marks the midway stage of the SFO’s five-year strategy. The previous 12 months (which were covered by the 2025-26 SFO business plan) have seen the agency publish guidance on matters ranging from corporate compliance programmes and information sharing through to corporate prosecutions and self-reporting and deferred prosecution agreements.
It is an organisation that does not seem to skimp when it comes to planning for the future. So, according to the aforementioned phrase at least, any failures should be few and far between.
The SFO’s business plan for the coming 12 months states that the agency can make great use of the same technology that white-collar criminals are abusing. It highlights the “significant opportunities’’ that it can take advantage of – and the agency is in little doubt that it will do just that.
With the April 22 arrest of four people on suspicion of conspiracy to defraud and conspiracy to make false representations as part of an SFO investigation into a £4 billion government-backed scheme designed to cut fuel poverty and slash carbon emissions, the agency could possibly argue that its new approach is already obtaining results. It suspects that the companies Warmfront, JJ Crump and South Coast Insulation Services defrauded energy companies out of £44 million by submitting claims in which little, or no, actual work was done.
Less than a week before the arrests, at the formal launch of the business plan, the SFO’s interim director Graham McNulty emphasised the agency’s “ambition and focus on our priorities, including intelligence-led investigations, innovative modern tools and effective disclosure’’ and of a determination to “increase the pace and efficiency of our work’’. There were references to proactive intelligence and (that word again) innovative skills and techniques being used by the SFO, as well as to making the most of new technology and developments to ensure “lean, precise and focused’’ operations.
Bold
Such declarations appear bold, at first glance. At the very least, they sound like the claims of an agency that thinks it has got the planning side of things all sorted out. But is that enough?
Making the most of technology and intelligence, being proactive and acting with speed and efficiency all sound inspiring. But surely this is what the SFO should have been doing since it came into existence. Every single investigating agency has to have as its reason for being the need to identify, prevent and / or punish wrongdoing as quickly as possible.
And very similar phrases relating to being proactive and quick case progress were being used by the then SFO Director Nick Ephgrave in 2024. He departed the SFO at the end of last month, having injected a renewed vigour and sense of purpose into the agency. The SFO now has to ensure it retains that momentum.
This latest plan can be viewed as the blueprint for that challenge. It makes it clear what the SFO’s goals are and how it believes they can be achieved. And even though some of its measures - and the strong claims in support of them – may not be 100% original, they at least indicate a willingness to make progress as an organisation.
Belief
There has to be, however, some scepticism about the SFO’s belief that harnessing the potential of technology will lead to greater pace, efficiency and focus as it goes about its work.
This is, after all, the agency that earlier this year had to make the embarrassing admission that serious issues with its IT disclosure system had affected 20 long-running cases. If the IT department is struggling that is hardly the best start to the proposed new era, especially when it is remembered that disclosure was already the SFO’s achilles heel, long before any bold pronouncements about unleashing the powers of technology were being made.
From this point on, it is up to the SFO to follow its plan and do what it can to meet the high ambitions contained within it. Nobody can fault the agency for its dedication to planning. What tends to result in criticism of the SFO is its inability to master some of the more real world challenges it faces. Some of which, it appears, no amount of planning can prevent.
So for now at least, it may be best to view the SFO’s stirring talk with caution rather than unlimited optimism.
