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Serious Fraud Office Annual Review

Issue 6: December 2025

Serious Fraud Office Annual Review

Editor's note

Johanna Walsh - Mishcon de Reya

Welcome to our sixth annual SFO Enforcement Review. In this review, we examine the SFO's activities in its second year under the leadership of its Director Nick Ephgrave QPM. We also look ahead to 2026 which promises to be a busy year for the SFO as it prosecutes three trials and continues to investigate ongoing cases.

Read the full note

News
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Ongoing investigations

The SFO is investigating a suspected fraudulent timeshare services scheme operating from at least 2018, involving 26 UK-based companies including Timeshare Legals Ltd, TSL Europe Ltd, and The Nobel Group of Companies.

2 mins
News
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Criminal proceedings/matters concluded

The Supreme Court has quashed the convictions of former bankers Tom Hayes and Carlo Palombo for conspiracy to defraud in relation to manipulating key benchmark interest rates - LIBOR and EURIBOR.

1 min
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Proceeds of crime results

In January 2025 the SFO secured over £1 million in assets through a confiscation order against Timothy Schools. Mr Schools had been convicted of defrauding investors into his Axiom Legal fund and was sentenced to 14 years' imprisonment. Mr Schools had been found to have hidden some of the proceeds of his crime by transferring some of the money to his family members under the pretext that these were loans.

2 mins
News
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Reviews and collaboration

In February the SFO provided an update on the ongoing review of its use of e-discovery software. The SFO currently uses the software OpenText Axcelerate to help it identify evidence and other material that is relevant to its criminal investigations and prosecution.

1 min
News
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SFO corporate guidance

On 24 April 2025, the Serious Fraud Office (SFO) released updated guidance on corporate cooperation and enforcement, marking a significant shift in its approach. Corporates that self-report and fully cooperate will now be invited to negotiate a Deferred Prosecution Agreement (DPA), unless exceptional circumstances apply.

1 min
News
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White collar crime and investigations: What to expect from the SFO in 2025?

In 2026, we can expect to see the Serious Fraud Office (SFO) continue to build upon its five year strategy, published in 2024. Those within the organisation may feel a considerable push to complete projects and deliver results in anticipation of a mid-point review of the strategy's content and direction, which was planned at the strategy's launch.

1 min

Serious Fraud Office Annual Review Issues

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