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

SFO updates corporate co-operation guidance and publishes new self-reporting guidance 

The Serious Fraud Office (SFO) has updated its corporate co-operation guidance on self-reporting suspected fraud, bribery and corruption and published separate guidance on making a corporate self-report. 

The updated guidance, which was first published in April 2025, now enables companies’ legal representatives to discuss a potential self-report directly with the SFO’s Director of Legal Services and General Counsel, Matthew Wagstaff, via a dedicated email address, before submitting a formal report. Companies are also able to request anonymity at this stage. The SFO states that the change offers a "swifter, clearer path" into deferred prosecution agreement (DPA) negotiations for corporates that engage early. 

The update also clarifies that companies should take a proportionate, risk-based approach to identifying the full extent of any criminal offending. It confirms that the six-month period within which the SFO aims to conclude DPA negotiations now runs from the point a company accepts an invitation to negotiate, rather than from when the invitation is issued, giving corporates a clearer and more predictable timeline. 

This update reflects the SFO's continued push to encourage companies to self-report at the earliest opportunity, by lowering the barriers to engagement and offering greater certainty over timing. Organisations should ensure that their internal reporting, investigation and escalation processes are robust enough to identify and address potential wrongdoing before any decision to self-report needs to be made. 

See the press release. 

BIST consults on whistleblowing reforms and SFO rewards scheme 

The Department for Business, Innovation, Science and Trade (BIST) has launched a consultation on reforming the whistleblowing framework under the Employment Rights Act 1996. It also seeks views on a proposed SFO financial rewards scheme for reporting economic crime and associated criminal offences. 

The key areas for consultation include: 

• a proposal for whistleblower rewards to be calculated as a percentage of any financial penalty or fine imposed on the company, with no proposed cap on the maximum value;  
• a new criminal offence for individuals who knowingly submit false information under the scheme, or who harass or intimidate whistleblowers who use it; and 
• whether the categories of reportable wrongdoing should be expanded to better capture risks arising from AI technologies and corruption-related misconduct. 

The consultation closes on 8 January 2027. 

Applications open for next director of the Serious Fraud Office 

The attorney general, Ellie Reeves KC MP, has officially opened applications for the next permanent director of the Serious Fraud Office, with the Attorney General's Office overseeing recruitment. The role is offered as a five-year fixed-term appointment, extendable for up to a further two years. 

As previously reported, the role has been filled on an interim basis by Graham McNulty since Nick Ephgrave’s retirement in April 2026. A permanent director is expected to be in place by early 2027. With the SFO's recent moves to encourage self-reporting and whistleblowing, the identity and priorities of the next director will be worth watching closely.