Bribery, fraud and anti-money laundering | UK Regulatory Outlook February 2026

SFO director announces retirement 

Nick Ephgrave, the director of the Serious Fraud Office (SFO), has announced that he will be stepping down from his role at the end of March. 

Mr Ephgrave joined the agency in 2023 and is currently halfway through his five-year tenure. During his leadership, the SFO published its five-year strategy for 2024-2029, focusing on proactivity, innovation and pace. 

He commented: "I believe we have achieved what we set out to do: create a rejuvenated SFO that is strong, confident, dynamic and pragmatic." Under his leadership, the SFO has commenced 13 investigations. 

This represents a loss of senior experience in complex multinational investigations at a point when the SFO has a larger caseload than in recent years. The mid-term departure also comes at a time of broader institutional uncertainty for the SFO.  

On 25 January, the government announced plans to establish a new National Police Service (NPS), which would combine the capabilities currently carried out by the National Crime Agency (NCA), the Counter Terrorism Policing and other regional crime units, under a single organisation. While the SFO is not mentioned in these proposals, the creation of the NPS has revived debate about whether the SFO should remain independent or be integrated into a broader enforcement structure – plans to merge the SFO with the NCA were included in the Conservative Party's 2017 election manifesto. 

Organisations should monitor developments closely to ensure they are aware of potential shifts in enforcement approach and priorities under new leadership, as any structural changes could significantly affect investigative resources, strategic priorities and operational performance. Ephgrave will remain in post until the end of March. An interim director will be appointed pending a formal recruitment process for his successor. 

SFO succeeds in High Court challenge on DPA enforcement 

In a significant ruling, the Administrative Court found in favour of the SFO in proceedings concerning breach of a deferred prosecution agreement (DPA). The court held that the DPA entered into by the company remained enforceable beyond its stated expiry date, where the company had failed to meet its payment obligations. 

The company entered into a DPA with the SFO on 22 October 2019 in connection with allegations that it had conspired to make corrupt payments to a South Korean official and had failed to prevent bribery. Under the terms of the DPA, the company accepted the charges and agreed to pay a total of £2,069,861, with payment due by 22 October 2024. 

The company failed to make the required payment by the deadline. On 21 November 2024, the SFO applied for a determination by the court that the company was in breach of the DPA. The company argued that the DPA was no longer enforceable on the basis that it had expired. 

The court emphasised that ordinary principles of contractual construction must be applied to the construction of a DPA such as the one in the present case. The court concluded that the DPA did not expire on 22 October 2024 in circumstances where payment had not been made, holding that "[v]ery clear words would be required" to demonstrate that the parties intended the company to be relieved of its obligation to pay any outstanding amounts after the deadline. The proceedings instituted by the SFO were therefore validly constituted and the Crown Court has jurisdiction to proceed to determine them. 

This decision represents the first publicised instance in which the SFO has pursued breach proceedings against a corporate DPA counterparty. The SFO's April 2025 guidance emphasises that co-operation remains a key factor in the SFO's willingness to negotiate a DPA. The case will serve as a helpful point of reference for organisations weighing the possible benefits and risks of engagement with a view to reaching a negotiated settlement. 

On 10 February, the High Court refused the company's application for permission to appeal the ruling to the Supreme Court. 

Documents from the investigation are available on the SFO website. See also our Insight on the SFO guidance on corporate co-operation and enforcement. 

FCA launches newsletter to spotlight enforcement work 

The Financial Conduct Authority (FCA) announced in April 2025 that it would retire its portfolio letters from the end of that month , replacing them with market reports containing communications relevant to different types of firms and insights from its supervisory work. 

It said that firms should refer to these reports and "Dear CEO" letters for guidance, the latter of which will continue to be used to address senior management about significant issues requiring action. The FCA has now launched a new newsletter, "Enforcement Watch", to provide insights and themes from its enforcement work. The launch issue was published on 28 January and covers developments in publicity policy, enforcement case priorities and international partnership. 

Publicity policy in action  

The FCA sets out its revised publicity policy, which retains the "exceptional circumstances" test, under which it may name firms or individuals subject to enforcement investigations only if certain criteria are met (see our previous Regulatory Outlook). Between June and December 2025, the FCA opened 23 enforcement operations, including 12 into authorised firms and six into individuals. 

Enforcement case priorities 

The FCA’s 23 enforcement operations are categorised as regulatory breaches (18 operations), criminal and regulatory offences (four operations) and criminal offences alone (one operation). 

Areas of focus include individual responsibility for regulatory failings such as providing false information, suspected fraud and misappropriation of funds, unauthorised business (particularly in the cryptoasset sector) and inadequate financial crime controls. 

The FCA has reminded firms of its supervisory approach, noting that enforcement is pursued where supervisory engagement has not resolved significant concerns. This includes cases of repeated failures to be open and transparent, failure to remediate identified issues, deliberately misleading the regulator or significant consumer harm. 

International partnership 

The FCA continues to strengthen its international enforcement capabilities through partnerships with global regulators and law enforcement agencies. This includes its membership of the International Organisation of Securities Commissions, under which members agree to share information to support each other’s enforcement activities.