BCL Partner Anoushka Warlow and Associate Megan Curzon analyse how the Serious Fraud Office (SFO) has evolved under the leadership of Nick Ephgrave, who marked two years as Director in September 2025.
Since his appointment, Nick Ephgrave has sought to make the SFO “bolder, more pragmatic, more proactive.” The agency has accelerated investigations, launched new cases, and achieved its first unexplained wealth order, recovering £1.1 million. Alongside this renewed activity, the SFO has also gained powerful new tools through the Economic Crime and Corporate Transparency Act 2023, including the failure to prevent fraud offence and an expanded identification doctrine, both designed to make corporate prosecutions easier.
Ephgrave’s approach has also focused on revitalising corporate cooperation. The SFO’s revised guidance in April 2025 aims to encourage companies to self-report wrongdoing, offering a clearer route to deferred prosecution agreements (DPAs).
Combined with strengthened international partnerships, a renewed emphasis on intelligence gathering, and calls to reform the whistleblowing regime, these changes signal a more confident and capable SFO.
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