UK Trends and Developments Contributed by: Neil Swift, Jasvinder Nakhwal, Charlotte Tregunna and Rachel Cook, Peters & Peters
SFO Strategy and Resourcing: 2025–26 Business Plan The SFO’s 2025–26 Business Plan, published in April 2025, sets an ambitious course for the agency. It con - firms increased funding and outlines a commitment to international collaboration, enhanced technology and faster case management. Key priorities include: • International co-operation: Strengthening ties with overseas enforcement bodies and aligning with the new UK–France–Switzerland taskforce. • Corporate co-operation and whistle-blower reform: Embedding the new co-operation guidance and developing proposals for financial incentives for whistle-blowers. • Use of technology: Expanding data analysis tools, upgrading case management systems and increas - ing digital forensics capacity. • Asset recovery: Pursuing proceeds of crime more aggressively, including through Unexplained Wealth Orders. For corporates, the message is straightforward: inves - tigations will move faster, use more technology and involve more cross-border co-ordination. Robust data management and early engagement with investigators will be essential. Technology and Artificial Intelligence in Enforcement The SFO is modernising its technological infrastruc - ture to manage cases more efficiently and analyse evi - dence at scale. The business plan highlights several advances: • A modern case management system that inte - grates workflows, document tracking and analyt - ics. • Use of Technology Assisted Review, which has proven up to 40% faster than traditional document review. • Expanded intelligence analysis tools and the capacity to trace cryptocurrency and digital asset transactions.
For businesses, these advances mean shorter time - lines, greater data scrutiny and higher expectations of digital readiness. Companies should ensure their data retention and e-discovery systems can support fast, defensible co-operation. They should also prepare for investigators to use predictive analysis and cross- database searches to uncover patterns that manual review might miss. Technology has become a defining feature of enforce - ment strategy. Companies must be prepared to meet regulators on this new, data-driven terrain. Whistle-Blowers and Cultural Reform The UK is moving towards a more supportive environ - ment for whistle-blowers. The SFO has voiced strong support for introducing financial incentives, and leg - islative reforms are under discussion. The Office of the Whistleblower Bill proposes an inde - pendent body to oversee disclosures, enforce stand - ards, monitor confidentiality and provide redress. It would also create a central reporting channel and a fund to support whistle-blowers. Meanwhile, proposed amendments to the Employ - ment Rights Act under the forthcoming Employment Rights Bill would expand the definition of protected disclosures and make it easier for workers to prove that reports are genuinely in the public interest. The law on non-disclosure agreements (NDAs) also changed on 1 October 2025, under Section 17 of the Victims and Prisoners Act 2024. Any NDA signed after that date is void to the extent that it restricts someone from reporting alleged criminal conduct to specified authorities. For companies, this means: • More potential whistle-blowers, including contrac - tors and third parties. • Increased internal reporting and scrutiny of NDAs and settlement agreements. • A need to update whistle-blowing policies, training and investigation processes.
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