Mark Beardsworth, Duncan Grieve, and Sharon Takhar discuss the SFO’s business plan for 2026-2027, in Law360

On 16 April 2026, the Serious Fraud Office (SFO) published its business plan for 2026–27, the first issued under the agency’s interim director following the departure of Nick Ephgrave. The plan arrives at an important moment for the SFO. Its contents suggest an agency less focused on headline-grabbing prosecutions and more concerned with strengthening the institutional foundations upon which effective enforcement of complex financial crime depends.

The plan identifies a number of clear priorities: greater discipline in case management, increased use of artificial intelligence and technology within disclosure processes, expanded capability in relation to crypto assets, and renewed emphasis on international co-operation. Taken together, these themes provide a useful indication of how the SFO views both its recent challenges and its future direction.

The more difficult question is whether the agency possesses the resources necessary to deliver on those ambitions.

In this article we shall discuss the SFO's stated priorities as articulated in its business plan including case management strategy, the use of technology and AI, focus on crypto assets and international cooperation with overseas law enforcement. We also evaluate the SFO's stated aims against its current capabilities and resources and extract practical takeaways for practitioners.

Disciplined Case Management and Lifecycle Controls

A notable feature of the plan is its emphasis on tighter case management and prioritisation. It points towards earlier triaging of matters, clearer governance structures, and closer oversight of long-running investigations. That focus is welcome and, arguably, overdue. The duration of certain SFO investigations has long attracted criticism from defence practitioners, the judiciary and Parliament alike. Investigations that continue for many years impose substantial costs on suspects, witnesses and public resources, whilst also undermining confidence in the administration of justice.

If implemented effectively, earlier triage may lead to more decisive decisions at the outset of investigations as to whether a matter justifies the deployment of the SFO’s limited resources. This may result in a greater number of early closures and may in some cases reflect a more focused enforcement strategy.

For corporations, the practical implications are significant. Businesses subject to SFO scrutiny may find that investigations move more quickly through key decision points. Whilst this may shorten periods of uncertainty, it will also require companies to engage promptly, with organised document preservation, clear communication channels with advisers, and robust internal investigation procedures already in place.

Technology, AI and Disclosure

A key element of the plan is the SFO’s stated intention to make greater use of artificial intelligence, automation and technology-assisted review within its disclosure processes. The plan refers to automated clustering, continuous learning models and other digital tools designed to reduce the manual burden associated with the substantial datasets that characterise modern financial crime investigations.

Disclosure has represented one of the SFO’s most persistent operational vulnerabilities. The collapse of several high-profile prosecutions following disclosure failures caused significant reputational damage and prompted both internal review and external scrutiny.

Against that background, the proposed use of technology is unsurprising. In large and data-heavy investigations, some form of technology-assisted review is increasingly unavoidable and indeed, beneficial. Properly deployed, such tools may improve efficiency, consistency and speed.

However, they are unlikely to eliminate controversy. Rather, the nature of disclosure enquiries may evolve. Challenges may increasingly focus on methodology: the reliability of review tools, the parameters applied to training models, the treatment of marginal material, and whether responsive documents have been overlooked.

For defence practitioners, a working understanding of these technologies is likely to become increasingly important. For corporations, investment in their own review capabilities may place them in a stronger position to co-operate efficiently and credibly with enforcement agencies.

There is also an important fairness element to be considered. Where prosecuting authorities rely on opaque or poorly understood systems, courts may be asked to consider whether defendants have been given a proper opportunity to scrutinise the process. This is likely to become an important area of procedural development in the coming years.

Crypto Asset Investigative Capability

The plan also signals an expansion of the SFO’s capability to investigate matters involving crypto assets. This is a logical development, reflecting the growing role of digital assets in fraud, sanctions evasion and money laundering cases.

Other domestic and international agencies have already invested heavily in this area. The Financial Conduct Authority, the National Crime Agency and overseas prosecutors have all increased their focus on crypto-related misconduct in recent years.[i] The SFO would have risked falling behind had it not done the same.

The more significant question is what enhanced capability means in practice. Effective enforcement in this area requires more than software tools. It depends on investigators, analysts and lawyers with sufficient expertise to understand blockchain tracing, decentralised structures, asset recovery and cross-border evidential issues, all of which require significant financial resourcing.

For corporations operating in sectors with exposure to digital assets, this development warrants careful attention. Existing anti-money laundering, fraud prevention and transaction monitoring controls may require reassessment to ensure they remain fit for purpose.

International Co-operation and Cross-Border Enforcement

The plan also reiterates the SFO’s commitment to strengthening relationships with overseas counterparts. That reflects the reality that serious fraud, bribery and corruption investigations are rarely confined to a single jurisdiction.

The ability to share intelligence, co-ordinate investigative steps and obtain evidence across borders is often central to successful enforcement outcomes. In the post-Brexit environment, those relationships may be of even greater importance, particularly where previous institutional mechanisms have changed or become less straightforward.[ii]

For multinational businesses, the practical lesson is clear. An SFO investigation will likely not be a purely domestic matter. Questions of privilege, employee interviews, document production and any potential resolution strategy may all carry consequences in multiple jurisdictions.

The Resource Question

Set against the ambitions of the plan, a central question remains whether the SFO has the resources to deliver meaningful change. Most of the plan’s priorities require substantial investment. Technology platforms, specialist disclosure teams and experienced crypto investigators are costly. Effective international engagement also requires sustained operational support.

The gap between strategic ambition and operational capacity has, at times, been a familiar issue for the SFO. If additional funding and recruitment do not follow, there is a risk that some of the plan’s objectives remain aspirational rather than transformative. 

Practical Takeaways

Corporates or individuals engaging with the SFO or considering doing so may wish to bear several points in mind.

First, if earlier triage and tighter case controls are implemented effectively, the initial stages of investigations are likely to become even more important. Early legal advice and immediate strategic planning will be critical.

Second, disclosure disputes may become more technical. Familiarity with review technology and data-handling processes is likely to become increasingly valuable.

Third, the SFO’s focus on crypto assets should prompt renewed scrutiny of client compliance frameworks where digital asset exposure exists.

Fourth, cross-border co-ordination should be assumed in any substantial matter with an international dimension.

Finally, the agency’s funding position should be monitored closely. It may provide the clearest indication of which priorities are likely to be pursued in practice.

Notably, the 2026–27 plan does not revisit whistleblower incentivisation, notwithstanding the prominence given to the issue in the SFO’s wider five-year strategy and in the 2025–26 business plan.[iii] That may simply reflect a decision to prioritise operational delivery in the near term, pending further consideration of more substantial policy reform.[iv]

Conclusion

The SFO’s 2026–27 business plan suggests an agency seeking to address longstanding operational weaknesses whilst adapting to the changing demands of financial crime enforcement. Its focus on case management discipline, modernised disclosure processes, specialist crypto capability and international co-operation is sensible and, in several respects, overdue.

Whether those priorities translate into meaningful operational change will depend less on the quality of the plan itself and more on implementation, leadership and resourcing. The coming year should provide a clearer indication of whether the SFO can convert strategic intent into practical delivery.

[i] https://www.fca.org.uk/news/press-releases/fca-first-enforcement-action-against-firm-enabling-cryptoasset-trading

https://www.fca.org.uk/news/press-releases/fca-action-against-htx-illegal-financial-promotions

https://www.fca.org.uk/news/press-releases/fca-continues-action-against-unregistered-crypto-atms-across-uk

https://www.nationalcrimeagency.gov.uk/news/fraudsters-targeting-cryptocurrency-stopped-and-12-million-frozen-in-nca-led-operation-atlantic

[ii] https://www.parliament.uk/business/lords/media-centre/house-of-lords-media-notices/2023/july-2023/post-brexit-uk-eu-security-cooperation-suboptimal-says-lords-committee/

[iii] https://assets.publishing.service.gov.uk/media/67ee4e86199d1cd55b48c6e8/SFO_2025-26__Business_Plan.pdf

[iv] https://www.gov.uk/government/speeches/director-ephgraves-speech-at-rusi-13-february-2024