Partner Chris Roberts discusses the recently published SFO business plan for the year ahead and the strategic thinking of the agency’s interim director, Graham McNulty, in Global Relay.

Chris’ article was published in Global Relay, 14 May 2026.

Five-Year Plans published by the former Soviet Union were monumental in scope and notorious for fabricating figures to present a false picture of success. Marking the midway point of its five-year strategy, the latest business plan from the Serious Fraud Office could not be more different in character and substance. Short (just over 1,000 words), succinct, and devoid of numerical data, it focuses instead on significant anticipated developments.

Published on 16^th April, the SFO’s Business Plan 2026-27 deals in words rather than numbers. Ostensibly, it outlines the strategic thinking of the agency’s Interim Director, Graham McNulty. But in bearing the distinct imprint of Nick Ephgrave, the former SFO Director who retired prematurely at the end of March, the plan is evidently a document drafted towards the culmination of his shortened tenure.

So, what does it include?

Setting out current challenges facing the SFO, disclosure obligations involving myriad documents are described as ‘monumental’ and the disclosure process, rightly, as ‘complex and difficult.’

The plan adds that criminals are capitalising on developments in technology: the increasing sophistication of AI makes it ‘easier for fraudsters to appear credible to potential victims.’

Similarly, crypto assets complicate the fight against money laundering: ‘Their speed and global reach allow criminals to hide the proceeds of crime with just the click of a button,’ according to the plan.

Divided into four pillars, the plan outlines strategic imperatives to deal with these challenges, increase operational efficiency and enhance the SFO’s position. The agency’s values are described as ‘professional, collaborative and innovative’ and the characteristics of its identity are summarised as ‘confident, strong, dynamic and pragmatic’ shaping ‘how we strive to work and serve as partners.’

The first pillar deals with the SFO’s ‘highly specialised, engaged and skilled workforce’, and prioritises the SFO’s mission and culture in making it ‘a great place to work, attracting highly skilled people.’ In practice, this requires the SFO going out into the market and saying: “There are opportunities here for you and your career that you will not get anywhere else.”

Beyond lawyers, that also applies to investigators and tech-focused individuals. As former Director Sir David Green recognised, there can be advantages in highly-skilled people joining the SFO for a year or 18 months, but who would otherwise not do so.

The plan confirms that the SFO is moving its headquarters later this year – from Canada House in Trafalgar Square to Cabot Square in Canary Wharf, where it will join other government organisations like the Competition and Markets Authority.

The second pillar outlines the use of technology as a means of combatting both disclosure obligations and criminal actors. ‘Automation, AI and big data all provide ways to radically change our approach to intelligence analysis,’ notes the plan. ‘Proactively tracking suspects and suspicious activity has never been so easy.’

Beyond increasing speed and efficiency and further improving organisational security and resilience, the SFO is launching a new AI roadmap ‘to capitalise on high-impact opportunities’ and implementing its first case management system.

Focused on combatting crime effectively through intelligence, enforcement and prevention, the third pillar has several aims: to deliver a prevention programme to provide corporates with the tools and incentives to prevent bribery and corruption; developing and maximising crypto asset investigation capabilities; and investing in ‘proactive intelligence’ to increase investigation sourcing, speed and precision.

The SFO also aims to deliver its 2026 Disclosure Improvement Plan and strengthen its digital forensic activities by progressing towards UKAS accreditation.

The final pillar focuses on the SFO’s role as a proactive, authoritative player in the global and domestic justice system. But its ambition is modest.

Hosting a conference with French and Swiss prosecutors may help to create networks and facilitate smoother investigations. But responding to part two of Jonathan Fisher KC’s “Disclosure in the Digital Age” review of the Government’s programme of criminal justice reform and the Financial Action Task Force (FATF) inspection of the UK framework are more reactive than proactive.

Notably, no mention is made of actively ensuring the viability and integrity of UK PLC on a global basis nor how to implement part of the SFO’s stated mission: ‘to protect the UK’s reputation as a safe place to do business.’

Understandably, SFO funding is also not mentioned in the plan. Arguably, it is the biggest challenge of all.

The justice system, like every aspect of the public sector, is crying out for more funding. Even HM Crown Prosecution Service Inspectorate recently stated that there are gaps in the SFO’s offering that are filled by the use of external counsel, but which should instead be plugged on a permanent basis.

The SFO could also push for changes in procedural rules, particularly around disclosure, which would make investigations more efficient, whilst balancing the rights of defendants: it is also in their interest that investigations are resolved in faster timeframe – something that Ephgrave picked up on.

But for the SFO to attract top legal talent, a concerted push is needed (underpinned by government support), alongside a review of how salary packages might be tailored to achieve this. Ultimately, there is only so much that the SFO can hope to achieve on its relatively modest budget. Its current plan is, therefore, a reasonable place to start in difficult economic times.