As 2026 kicks off, the U.K. Serious Fraud office (SFO) is pursuing a more proactive and streamlined enforcement regime while making it simpler and faster for organizations to comply with financial crime prevention regulations.
This post provides an overview of the four specific improvements made by the SFO and their impact on organizations and their financial crime compliance teams.
#1: The SFO is taking real enforcement action, faster
The Serious Fraud Office (SFO) has long suffered from either not enforcing regulations already on the books as well as slow enforcement. In speaking about the offense of ‘failure to prevent fraud,’ SFO Director Nick Ephgrave stated recently, “Time is running short for corporations to get their house in order or face criminal investigation…Come September [2025], if they haven’t sorted themselves out, we’re coming after them…We can’t sit with the statute books gathering dust, someone needs to feel the bite.”
In late November 2025, the SFO executed coordinated dawn raids connected to its investigation into “Basis Markets,” a fraudulent cryptocurrency investment scheme. Demonstrating a multi-agency approach to enforcement, the SFO raids were performed in coordination with local police departments and supported by Solicitor General Ellie Reeves. According to Reeves, “I will resolutely support the Serious Fraud Office to tackle the scourge of cryptocurrency fraud and protect consumers.”
#2: New DPAs prevent crime and offer offenders less painful resolutions
The SFO has also promised faster and less expensive resolutions for offending organizations. Organizations that have failed to prevent fraud can now self-report and enter into Deferred Prosecution Agreements (DPAs). By doing so, they admit to guilt but limit the amounts of fines and penalties they incur. They also save themselves brand damage and the high costs of defending themselves in both the courts and the press.
In order to take advantage of DPAs, companies will have to assess their issues shortly after discovering them and decide quickly whether to self-report. As such, they will need to have strong corporate controls in place related to discovery and escalation surrounding suspicion of fraud.
Here’s how DPAs work for a typical U.K. bank:
A trigger event occurs: For example, the bank discovers potential criminal wrongdoing (e.g., enabling fraudulent activity) and self-reports to prosecutors, or authorities uncover it.
The bank and SFO negotiate: The bank enters into discussions with the SFO prosecutor about DPA terms.
Conditions are set: The bank must agree to:
- Pay significant financial penalties and disgorge illicit profits.
- Pay compensation to victims.
- Implement robust new compliance programs.
- Cooperate fully with investigations.
The court approves the DPA: A judge must approve the DPA, ensuring it’s in the public interest and terms are fair, reasonable, and proportionate.
Bank acts on the DPA: If the bank meets all conditions over a set period of time, the criminal charges are dropped. If the bank fails to meet them all, prosecution will occur.
#3: The SFO has made faster investigation commitments
The SFO has promised to streamline case handling. Specific commitments include the following:
- SFO will contact a self-reporting organization within 48 hours of filing a self-report.
- SFO will provide the self-reporting organization with a decision about a potential investigation within six months.
- Following a decision to investigate, SFO will conclude DPA negotiations within an additional six months.
These commitments should help to change the current public perception that the SFO is always slow to act. How slow? Well, on January 12 of 2026, the SFO finally returned £400,000 to nine victims of a Lebanese Banker’s £4.4m fraud that took place 24 years earlier.
#4: SFO will pursue illicit funds without a conviction
While the Lebanese banker fraud case took a long time, the fact that funds were eventually returned underscores a new paradigm—SFO will now return recovered proceeds directly to victims AND without an actual conviction taking place.
Prior to this case, SFO paid funds to the HM Treasury. But this case highlights a significant development in U.K. proceeds of crime enforcement. Organizations tied to cases now face risk in exposed asset-holding structures, historic exposure, sanctions risk, and long-term financial crime liability. Again, this applies even without a criminal conviction.
For any bank’s financial crime compliance team, gaining closer familiarity with the SFO’s more proactive and robust enforcement regime is a ‘Must Do’ in 2026. Deciding how effective the new measures and rules are will take some time to play out. But what is certain is that banks should have in place the top-level commitment, risk assessment capabilities, and ongoing monitoring processes and tools in place to enable rapid response in the event of adverse financial crimes taking place among its customer base.
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