Clifford Chance

The SFO's latest annual report (published on 10 July) confirms that the organisation has taken time to consolidate. Levels of publicised enforcement activity have remained relatively low for much of the year. Its budget has remained relatively static. There is a continuing focus on efficiency and international collaboration.

Key takeaways – The SFO's year in numbers

• Budget increased in 2024/25 was £99.8 million (from £95.5 million in 2023/24)
• Approximately 130 open cases (including criminal, civil, proceeds of crime and international assistance cases)
• Approximately 1,450 referrals to the Intelligence Division (up from approximately 1,300 referrals in 2023/24), including 167 whistleblowing disclosures
• Eight new criminal investigations opened and eight closed
• No further deferred prosecution agreements concluded
• 11 individuals charged across two cases
• Four major multi-site operations conducted to seize material (during which six individuals arrested)
• Average duration of cases from commencement of investigation to the first Court outcome stands at 4.3 years, slightly improved from the previous year (with one case moving from commencement to charges against five individuals within 15 months)

The report emphasises the steps the SFO has taken towards each of the four key outcomes set out in its five-year strategy and 2029 vision, published last year:

1. A highly specialised, engaged, and skilled workforce

2. Readiness to harness technology and tools of a changing world

3. Effective combatting of crime through intelligence, enforcement, and prevention

4. A proactive, authoritative presence in the global and domestic justice system

Through judicious case selection and revisions to key guidance, the SFO has sought to demonstrate commitment both to sending a strong deterrent message in appropriate cases and concluding settlements with co-operating corporates following self-reports. For example, new, more nuanced, Corporate Co-operation Guidance released in April 2025 emphasised the benefits of self-reporting and genuine co-operation. This was closely followed by one new prosecution and one new investigation concerning alleged failure to prevent bribery in connection with overseas conduct in Ecuador and the Netherlands respectively. See our blog posts on these developments here and here.

The SFO has previously held up its most recently commenced prosecution (concerning Mr Jose Alejandro Zamora Yrala, the former director of aircraft parts supplier AOG Technics Limited, who the SFO is prosecuting for alleged fraudulent trading) as a further illustration of efficient and effective collaboration with international counterparts (in that case Portuguese authorities). In the public statements accompanying the charging decision in that case, the Director of the SFO lauded a "focussed and fast paced investigation", adding that he was "proud that [the SFO has] acted swiftly, together with our European partners, to bring this important case to charge in just 19 months". This followed charges being brought within 15 months of the commencement of the investigation in a separate case concerning individuals connected with the collapse of the law firm Axiom Ince.

The report reiterates clear public commitments to maintaining profile and collaborating internationally. Examples have included the launch of a taskforce with French and Swiss counterparts (see our blog post here) and, more recently, accession to the International Anti-Corruption Coordination Centre.

However, there are reminders that, whilst the SFO is aiming to demonstrate its "authoritative presence in the global and domestic justice system", other UK enforcement agencies have overlapping remits and similar objectives. For example, the Crown Prosecution Service (further to an investigation by the National Crime Agency) is currently prosecuting Mr Zuneth Sattar on 18 counts of offences under the Bribery Act 2010 in connection with alleged payments to prominent former members of the Malawian government.

The report confirms the SFO's steady rollout of new technology. This has taken the form of the expanded use of Technology Assisted Review during the disclosure phase further to a pilot conducted over the past year and the procurement of a new case management system.

The year to come

The report, together with the SFO's 2025/26 Business Plan released earlier this year, describe an organisation aiming to maximise the impact of its finite resources in a changing global enforcement landscape.

One notable way in which it has indicated it is seeking to do so is through collaboration with the private sector, other government departments and academia in relation to a programme aimed "to help companies to protect themselves from the threat of serious fraud, bribery and corruption". No further details about what this may look like in practice, the extent to which the SFO may encourage corporate organisations to seek (or which it will be prepared to give) approval of their compliance programmes have yet been released, but the SFO has indicated that it will continue the implementation of this programme throughout 2025/26.

This annual report has been released at a time when it is less clear than ever that US criminal enforcement authorities will necessarily take the lead in cross-border fraud and anti-corruption investigations (see our blog post here). It has arrived shortly before important additions to the prosecutorial toolkit as the new corporate offence of failure to prevent fraud becomes available to the SFO (from 1 September 2025).  

In the report and elsewhere in other public statements, the Director of the SFO has committed to continued proactivity, although he has left himself considerable room for manoeuvre as to what this may look like in practice. Alongside warnings that announcements about investigations and prosecutions concerning the new corporate offence may follow relatively swiftly after its entry into force in some cases are continued reminders from the SFO of the possible advantages of engagement. There are some early indications that, in time, the emphasis could shift further towards joint efforts aimed at prevention involving collaboration between the SFO and the private sector. Any further indications released during the course of this year about what these interactions may involve will be instructive for corporates designing and refining their compliance programmes.

However, for now, corporates should assume that, having spent recent years re-grouping, increases in SFO enforcement activity may follow in the coming year as the SFO seeks to further reassert its authority.