Welcome to our fifth annual SFO Enforcement review.
In this review we look into the SFO's activities in its first year under the leadership of its Director Nick Ephgrave QPM.
This year saw the SFO announce three new investigations into Signature Group, Carlauren Group and the Thales Group respectively.
The new investigations continued in part the trend that we discussed in last year's review of the SFO choosing to focus its attention on domestic fraud. However, the investigation into suspected bribery and corruption involving the multinational aviation and defence electronics company, the Thales Group, does see the SFO turn its attention to the type of cross-border bribery cases that many had become accustomed to seeing it pursue in recent years.
We then turn our attention to what promises to be a potentially busy 2025 for the SFO. The new year will see the SFO prosecute two trials. The first concerns an alleged fraudulent investment scheme involving Ethical Forestry Limited and the second involves alleged fraud committed by four individuals in connection with the collapse of Patisserie Valerie Plc.
The coming year will also see the corporate failure to prevent fraud offence come into force. The Government guidance for this new offence, which partners from our team were involved in helping to formulate, was released in November.
Nick Ephgrave has already stated that he wants the SFO to be the first agency to bring a prosecution for this new offence. This, together with the changes to corporate criminal liability which came into force at the end of last year, means that 2025 is potentially going to be a very busy year for the SFO.