Serious Fraud Office’s new business plan signals continuity – and a new director keen to sustain momentum

Introduction

The Serious Fraud Office’s new Business Plan for 2026-27 published on 16 April 2026 is, on its face, a continuity document. It presents the agency as halfway through its existing five-year strategy and casts Graham McNulty’s interim leadership as an effort to build on Nick Ephgrave’s foundations rather than depart from them. The same priorities remain: intelligence-led investigations, modern technology, disclosure reform, stronger international coordination and a more confident public posture.

McNulty’s remarks at GIR’s Annual Investigations Meeting in London the same day broadly matched that message; he will not be the architect of a wider strategic rethink but rather  an operations-focused leader determined to keep momentum going, get the infrastructure right and preserve the sense that the SFO has become faster and more visible over the past few years.

Context and background

The Business Plan contains a number of concrete delivery items. These include a new AI roadmap, the SFO’s first case management system, more use of technology in intelligence analysis, further work on e-discovery, mainstreamed technology-assisted review, a 2026 Disclosure Improvement Plan, stronger crypto asset capability, and progress towards UKAS accreditation for digital forensics. It also repeats familiar themes about proactive intelligence, prevention, international cooperation and better use of Spending Review funding to act earlier.

The document is managerial rather than ideological. It is about execution, systems and capability. Even where it refers to emerging threats such as AI-enabled fraud or crypto assets, it does so through the lens of operational readiness rather than any wider strategic thinking.

McNulty’s remarks at the GIR Conference were consistent with that approach. He repeatedly described the SFO as being on the up, credited Ephgrave with energising the organisation, and stressed the importance of maintaining momentum. He returned several times to operational matters: the upcoming office move to Canary Wharf, the new case management system, the use of AI in disclosure-related work, the quality of staff tools, and the need to keep people engaged and motivated. As the SFO’s former COO, McNulty is well versed in the agency’s operational challenges.

Analysis

It is clear that the interim Director said he understands fraud, intelligence and large organisations, but that getting the infrastructure, training and management culture right is key to making the SFO effective. That is consistent with the Business Plan, which puts the emphasis on systems, workforce development and internal capability.

Disclosure was the clearest example of this. McNulty described it as the SFO’s single biggest challenge. That diagnosis matters because it is grounded in the agency’s day-to-day reality rather than its public messaging. The Plan reflects the same concern, but McNulty gave it more force. He explained that the issue is not complexity so much as scale: huge data volumes, digital material and the practical difficulty of reviewing what now runs into millions of documents. That point carries extra weight given the SFO’s well-documented problems with its Autonomy disclosure review system. Against that background, his emphasis on technology, AI tools and the case management system was not incidental. It reflected a view that fixing disclosure is central to restoring confidence in the agency’s ability to run complex cases properly.

McNulty also showed how strongly he believes in intelligence. The Plan refers to proactive intelligence and earlier intervention, but McNulty went further in person. He spoke about whistleblowing and inside information as being pivotal to progressing investigations, drawing on his own experience of intelligence-led work. Most notably, when challenged from the floor on whether the SFO was drifting away from major corporate cases and towards less complex investment fraud work, he did not retreat from that ambition. Instead, he suggested that one constraint on the SFO’s ability to get to the heart of large cases is the comparative lack of covert or intrusive tools of the kind he had used elsewhere in law enforcement, and he indicated that he wanted to explore whether more of those capabilities could be made available. The Business Plan says little about such powers.

Even so, the overall effect of both the Business Plan and McNulty’s interview was not to announce any bigger change. McNulty did not provide any in sight on how senior manager attribution under ECCTA would affect enforcement going forward and did not engage with the idea that changes in US enforcement might create an opportunity for the SFO internationally, rather referring to continued international cooperation.

Ephgrave helped galvanise the SFO partly through visible action: raids, faster decisions, stronger rhetoric and a sense of movement. McNulty clearly wants to maintain that approach. But it is not yet clear whether his period as interim director – likely to last for the rest of 2026 – will give the SFO the clear strategic direction it needs. The risk is that momentum stalls while the agency waits for a permanent director.

Takeaways

• Continuity is the order of the day. The direction of travel remains faster investigations, earlier intelligence development and a more active SFO.
• Check that speak-up channels are up to date and ready for possible legislative change. McNulty’s focus on whistleblowing and insider information suggests these routes will continue to matter.
• Be ready for a more intelligence-led agency. Internal concerns, third-party information and early red flags of misconduct may carry more weight than before.
• Expect the SFO to keep pushing technology and speed. Companies should make sure document preservation, data access and investigation readiness are in good order.
• Do not assume the agency’s focus on operational improvement means large corporate cases have fallen away. The pressure to show results under the failure to prevent fraud offence will only grow. 

Authored by Reuben Vandercruyssen, Claire Lipworth, and Olga Tocewicz.