Author: Nicola Sharp
26 May 2021
3 min read
Nicola Sharp of Rahman Ravelli details the main points in the Serious Fraud Office’s Business Plan for 2021-22
The Serious Fraud Office’s recently-published Business Plan for 2021-22 details the action it will take in four priority areas in the next 12 months in order to meet its strategic objectives.
The plan outlines how the SFO will fight complex economic crime, deliver justice for victims and protect the UK’s reputation as a safe place to do business. As has been the case in previous years, the plan describes the agency’s intentions in the areas of operations, people, stakeholders, and technology.
SFO Director Lisa Osofsky has said the Business Plan has been devised to continue building on what she calls the “substantial progress’’ the agency has made during the past 12 months in meeting last year’s objectives; including operational streamlining, enhancing relationships with external stakeholders and investing in technology for casework.
The Business Plan states that the SFO intends to deliver a new case progression project to ensure “high-quality case progression at pace’’. It also says the SFO aims to put victims and the public interest at the heart of its casework, with each case set to have a Victim and Witness Strategy so that attention is paid to their care through the life of a case. The SFO has stated that enhancing the recovery of the proceeds of crime and securing compensation for victims is a priority. It will, therefore, be investigating opportunities following SFO confiscation orders to recover further assets, identifying possibilities for asset forfeiture on SFO investigations and prosecutions under the Criminal Finances Act 2017, and working with international partners to pinpoint other situations with the potential for civil recovery.
While looking to encourage good corporate compliance and continuing to deploy deferred prosecution agreements where they are appropriate, the SFO intends to continue to focus on its intelligence capability. The Plans states the aim of embedding an intelligence culture at the SFO and motivating it to identify and generate the right intelligence. To do this, it will focus on four themes: international bribery and corruption in a changing world, the 2021 threat landscape, investment fraud and cryptocurrency. It believes it will enhance its intelligence gathering capabilities by focusing on these areas and being specific about the information it wants to collect.
The SFO is to deliver stage 2 of its three-year Culture Change Programme, which was created last year in response to the Leadership Review prepared by Her Majesty's Crown Prosecution Inspectorate, which was critical of aspects of the agency’s approach to management.
Stage 2 will include introducing an Action Learning Set (ALS) programme for all Band A (Grade 6) managers, reverse mentoring of senior managers by colleagues from diverse backgrounds and increasing staff representation in the Culture Change Programme. A new approach to performance management is being piloted, involving 20% of SFO staff. The agency is also creating a new Learning and Development portal to improve access to opportunities and provide career advice. It is now planning for the move from its current premises in 2022-23.
The 2021-22 Plan says the agency intends to use a new, strategic engagement strategy to promote its work and enhance its relationships with stakeholders; including re-establishing face to face contacts when COVID-19 restrictions are lifted.
It will continue utilising loans and secondments to and from its international partners after the pandemic.
The SFO’s technology priorities include enhancing its core IT platform, expanding its capability to manage and exploit data and using technology to further support case progression.
It intends to achieve this by increasing the collaboration capabilities of its existing IT platform - including delivering external video-conferencing tools – and by improving the capacity and responsiveness of its digital forensics and e-discovery services. It also intends to continue moving cases onto its current review platform, so that more case teams can benefit from its advanced data analysis capabilities.
The agency is looking to build up its skills in areas including cyber security, data, cloud technologies and digital forensics.
In the Plan, the SFO has said it will develop specific outcome delivery measures to monitor and report its progress.
The SFO has spent 2020-21 devising a network of boards and committees that will be responsible for overseeing and managing risks associated with delivery of the Business Plan.
The SFO Board sets the strategic direction and provides the senior leadership and scrutiny. The Executive Committee (ExCo) is responsible for organisational strategy and the decision making, oversight of and accountability for delivery of objectives. The Audit and Risk Committee is a peer committee to the ExCo that supports and advises the Accounting Officer (the Director of the SFO) and ExCo on issues of risk, control and governance.
Once it has been devised, the SFO’s Strategic Plan from 2022-23 will set the framework for the next three years of the SFO’s annual plans. This new Strategic Plan will set the direction for the SFO and its priorities.
Nicola is known for her fraud, civil recovery, arbitration and business crime expertise, her experience of leading the largest financial disputes and multinational investigations and her skills in devising preventative measures and conducting internal investigations for corporates.