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2025 signalled a major turning point in financial crime enforcement and regulatory compliance. The introduction of the “failure to prevent fraud” offence on 1 September 2025 significantly expanded corporate criminal liability, while the Serious Fraud Office (SFO) issued revised corporate guidance and adopted a more proactive approach, including the increased use of dawn raids and a drive to expedite investigations and charging decisions.
Meanwhile, the Financial Conduct Authority (FCA) continued to develop its data-driven regulatory model, focusing on targeted, high-impact investigations while using artificial intelligence (AI) and advanced analytics to detect misconduct earlier.
This article explores the key developments likely to shape the 2026 enforcement landscape, including recent changes and upcoming SFO trials, the creation of the National Police Service (NPS), reforms to the jury system, emerging business crime strategies, and enhanced anti-money laundering initiatives.
All change at the SFO
The biggest shock of the year has been the announcement that Nick Ephgrave will be stepping down from his role as the Director of the SFO, some two and a half years early. Little is known at this stage about the reason(s), with sceptics raising the historic noise on whether talk of merging the UK’s flagship agency with the NCA (National Crime Agency) will resurface.
There is no doubt that Nick Ephgrave’s tenure has brought about a marked change in the SFO’s task of fighting corporate crime, with more domestic investigations being opened up – a shift from the block-busting international ones that we are so accustomed to. Dawn raids have also seen a new resurgence, with more dawn raids being undertaken in the last two years than there have been in the three years before. Ephgrave has also seemingly brought about a police approach to investigations, with quicker results than the SFO is known for. An example being the Axiom Ince prosecution, which was turned around in 15 months from the investigation’s announcement.
What will come of the SFO remains to be seen, and while there will be an interim Director overseeing the agency’s work in the upcoming months, the next permanent posting will say a lot about whether the agency stays the course set by Ephgrave, or seeks to return to old ways.
The UK’s new ‘FBI’?
In a further string of headline-grabbing news, the Home Secretary announced the creation of the National Police Service (NPS), designed to bring new zeal to tackling crime across the UK. Due to be fully expanded on in a white paper on 26 January 2026, the National Police Service will be run by a national police commissioner who will take the role of the most senior police chief in the country.
The NPS, which will see a merging of the National Crime Agency with other regional crime units, also aims to free up local forces to tackle low level offending. The Home Secretary noted that, with the current approach to policing being out of date, the proposed changes will pool intelligence to increase public confidence that the level of security afforded to them is the same, no matter where they reside.
One query that is being discussed in the legal world is whether the NPS will be the death-knell to the SFO.
SFO Trials
Notwithstanding the departure of the current Director, 2026 is set to be a pivotal year for the SFO, with a number of trials scheduled, with business crime practitioners watching developments closely. While the agency secured a conviction against AOG Technics Limited at the end of 2025, the forthcoming trials will be a key test of its enforcement strategy and will place particular focus on Nick Ephgrave’s term as Director, following a period of historic unsuccessful prosecutions.
The first case listed for trial at Southwark Crown Court on 2 February 2026 involves three directors accused of running a fraudulent investment scheme linked to tree plantations in Costa Rica. On 16 January 2026, all three former directors of Ethical Forestry Limited pleaded guilty to conspiracy to commit fraud by false representation, ahead of the scheduled trial. This early conviction marks the SFO’s first success of 2026 and signals a focus on tackling investment fraud. This will reinforce the message that complex investigations will be pursued to hold perpetrators to account and protect the public.
Other notable cases this year include:
- Bribery prosecutions of former senior executives of Petrofac, accused of offering payments or profit shares to associates in the UAE to secure oil development contracts. The trial is listed on 5 October.
- Fraud charges against former executives of Patisserie Valerie, alleging they conspired to inflate cash balances between 2015 and 2018 by providing false documents to auditors. The trial is due to begin on 20 April.
- Two men accused of running a fraudulent car leasing investment scheme are scheduled to appear at Southwark Crown Court in Mid-September.
On 11 May, the SFO will defend its largest-ever asset seizure in a test of its confiscation powers. Former Petrobras executive Mario Ildeu de Miranda, whose conviction was quashed, seeks to have $7.7 million unfrozen following its seizure in a major money laundering investigation, marking the first appeal of a SFO account forfeiture order.
Over in the civil courts, Eurasian Natural Resources’ Corp., continues to pursue damages it claims are owed following a controversial criminal investigation. The mining company is seeking up to $290 million from the SFO, alleging the agency mishandled its investigation into allegations of fraud and corruption, with confidential information allegedly leaked to investigators by a city law firm embroiled in the controversy. The case is listed for trial on 20 April.
A strong run of results would allow the SFO to dispel its image of slow and ineffective enforcement and send a clear signal to corporates that misconduct will be met with prosecution. However, poor outcomes would likely revive familiar criticisms of the agency’s track record in bringing successful cases.
Trial by Jury
In December 2025, the UK government unveiled wide-ranging proposals to reform the criminal court system, with the stated aim of reducing trial delays and improving efficiency. If progressed, 2026 could see the most radical overhaul of the jury system in England and Wales to date.
The proposed reforms include:
- Establishing new “swift courts” in which cases expected to attract sentences of up to three years would be heard by a judge sitting alone, without a jury.
- Introducing judge-only trials for complex and highly technical fraud and financial crime cases.
- Extending magistrates’ sentencing powers to impose custodial sentences of up to 18 months.
Together, these measures would fundamentally reshape how criminal cases are allocated, tried, and sentenced, with significant consequences for defence strategy, legal advice, and the management of cases. Implementing these reforms would require extensive changes to primary legislation, the Criminal Procedure Rules, evidential frameworks, and practice directions.
The proposals would remove a defendant’s right to elect a trial by jury where the “likely” sentence is below three years’ imprisonment, going beyond Sir Brian Leveson’s recommendations in his Independent Review of the Criminal Courts, which suggested restricting jury trials only for offences carrying a maximum sentence of two years or less.
These reforms are expected to be introduced in 2026 and are already facing strong opposition in Parliament, following criticism from both legal professionals and civil society groups. The measures build on Sir Brian Leveson’s broader call for structural reform of the criminal justice system. This includes encouraging earlier guilty pleas, reclassifying certain either-way offences, restricting access to the Crown Court, and introducing alternative trial models for complex fraud cases. A further report by Sir Brian Leveson, focused on efficiency and the use of technology, is due in 2026, and may prompt additional reforms. Any reduction in jury trials is likely to remain highly contentious.
Business Crime Strategies
At the end of 2025, the UK Government published its Anti-Corruption Strategy, setting out 123 commitments aimed at tackling corruption both domestically and internationally.
The UK Anti-Corruption Strategy sets out several key commitments, including establishing and expanding a new Domestic Corruption Unit with £15 million in funding for the City of London Police, harnessing AI to speed up investigations, centralising the anti-money laundering and counter-terrorist financing supervisory functions currently spread across the UK’s 22 professional services bodies, and stepping up enforcement action against professional enablers such as bankers, accountants and legal professionals
Although the strategy introduces limited new policy initiatives, most having been previously specified, it reaffirms the Government’s commitment to combatting corruption and financial crime. Commercial organisations will be a particular focus, with increased scrutiny of professional enablers and greater incentives for whistleblowers. Businesses should therefore ensure their anti-corruption frameworks remain current, proportionate to risk, and aligned with the heightened emphasis on domestic corruption.
Two further major strategies aimed at reducing corporate economic crime are due to be published and rolled out in 2026: the Fraud Strategy, due in January 2026, and the Anti-Money Laundering and Asset Recovery Strategy, expected later in the year.
Anti-Money Laundering Reforms
In 2026, steps will be taken towards establishing a single professional services supervisor for money laundering. In 2025, HM Treasury published its response to the consultation on Reform of the Anti-Money Laundering and Counter Terrorism Financing Supervision Regime, appointing the FCA to assume the new supervisory role. Development of the new framework is likely to continue, with potential implementation in 2026, placing firms such as legal services providers, accountants, and trust and company services providers within the FCA’s supervisory remit where they are subject to the Money Laundering Regulations.
In the year ahead, we may also see the first corporate prosecution for failure to prevent fraud under the Economic Crime and Corporate Transparency Act 2023. The SFO has indicated that it will not hesitate to take action where companies fall short of their new duties.
United Kingdom