On 10 July 2025, the Serious Fraud Office ("SFO") published its Annual Report and Accounts for 2024–25 (the "Annual Report"), which provides an overview of the SFO's performance, strategic objectives and financial activities. This report marks the first year of the SFO's current five-year strategy (2024-2029). We commented further on the SFO's strategy in this previous post.
Since April 2024, the SFO reported it has:
- Opened eight investigations;
- Made six arrests and charged 11 people;
- Conducted four major multi-site operations to seize material across three cases; and
- Recovered £1.3m in criminal proceeds.
No deferred prosecution agreements ("DPAs") were reported.
Overview
According to the Annual Report, the SFO has an active caseload of around 130 cases, including around 35 open criminal cases (these are the same as the figures quoted for 2023/24). Its budget for this period was reported as £99.8m (an increase of 4.5% from £95.5m in 2023/24) and its staff count was reported as 550. The Annual Report noted decreases in the SFO's vacancy rate (13.1% from 16.3% in 2023/24) and turnover rate (13.2% from 16.6% in 2023/24).
In terms of performance, the SFO reported that it opened eight new investigations, charged 11 people, took one criminal case to trial and closed eight cases. The Annual Report notes that the time taken from formally opening an investigation to obtaining the first outcome has fallen to 4.3 years (down from 4.4 years in 2023/24).
Key highlights reported in the Annual Report include the following:
- The SFO secured a 30-month prison sentence and a £123k confiscation order against Jeffrey Cook, a former Ministry of Defence official, following his conviction for accepting secret payments in exchange for commissioning work from offshore consultants.
- The SFO secured the conviction of former investment manager David Kennedy for his role in a £100m investment fraud.
- Six people were charged in relation to allegations of corruption to benefit Glencore's oil operations in West Africa.
- Dr Gerald Smith, currently in prison for Covid loan fraud, was imprisoned for an additional 13 months for obstructing the SFO from seizing his properties.
- The SFO secured £1.3m in proceeds of crime, including over £1m in a confiscation order against Timothy Schools, a convicted solicitor found to have hidden the proceeds of a wider fraud. The SFO also secured its first Unexplained Wealth Order ("UWO") against Mr School's wife in connection with the same fraud. (See our previous post for further detail).
In November 2024, the SFO reportedly informed the High Court of its belief that Guralp Systems Ltd breached the terms of its DPA from 2019, reflecting the first time that the SFO has notified the courts of a possible breach of a DPA.
Tools and technology
The Annual Report refers to efforts by the SFO to strengthen its cooperation with international agencies, including through the creation of an anti-bribery and corruption task force with France's Parquet National Financier and Switzerland's Office of the Attorney General, and through signing a refreshed memorandum of understanding with its Indonesian counterpart.
In terms of technology (a key element of the SFO's strategy), the SFO reportedly rolled out a cloud based document management system and completed a pilot of its 'technology assisted review' program with positive initial findings. The SFO also reported a fall in the risk rating associated with its technological infrastructure not delivering on its expected service (downgraded from 'Very High" in 2023/24 to 'Medium' in 2024/25).
Future plans
In 2025/26 the SFO will begin preparing for a mid-point review of the content and direction of its five-year strategy, accounting for any changes in the SFO's operating context.
Commentary
The Annual Report reflects a relatively steady year in terms of performance for the UK's principal anti-fraud agency, with slight improvements across key various performance metrics and the SFO assessing itself to have "laid strong foundations" and taken "confident first steps" towards the aims of its current strategy.
With the SFO securing its first UWO and indicating its preparedness to take action to enforce DPAs, the Annual Report can be viewed as emphasising its willingness to employ a wider range of tools at its disposal. At the time of writing, the SFO had also just announced its freezing of over £10,000 worth of crypto assets belonging to a suspect in an ongoing investigation, representing the first time it has used newly granted powers to obtain a Crypto Wallet Freezing Order (these were introduced in April 2024 as one of the reforms introduced by the Economic Crime and Corporate Transparency Act 2023). There will be interest in whether these efforts continue, and ultimately result in successful prosecutions, by the time the SFO publishes the mid-point review for its current strategy, expected in 2026/27.
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