The Serious Fraud Office (“SFO”) is the United Kingdom’s specialist agency responsible for investigating and prosecuting complex cases of serious or high-value fraud, bribery, and corruption. Established in 1988, the SFO plays a central role in maintaining financial integrity and public confidence in the UK’s corporate and financial systems.
This article explores how SFO investigations work, the legal powers available to investigators, and the implications for companies and individuals.
What Triggers an SFO Investigation?
The SFO investigates the most serious economic crimes, particularly those involving:
- Large-scale corporate fraud
- International bribery and corruption
- Complex financial misconduct
- Fraud affecting multiple victims or involving significant public interest
Cases are typically referred to the SFO by law enforcement agencies, regulators, whistleblowers, or government departments. The decision to open an investigation is guided by the Director of the SFO, who considers factors such as complexity, scale of loss, and whether specialist expertise is required.
Many SFO investigations involve offences under legislation such as the Fraud Act 2006, the Bribery Act 2010, and the Criminal Justice Act 1987.
Key Powers of the SFO
Under Section 2 of the Criminal Justice Act 1987, the SFO can:
- Compel individuals to answer questions during interviews
- Require the production of documents or information
- Conduct search warrants and seizures
- Require companies to provide electronic data and records
Failure to comply with a Section 2 notice without reasonable excuse is a criminal offence.
These compulsory powers mean that individuals questioned by the SFO must carefully consider their legal position and often require tailored legal advice.
The Investigation Process
SFO investigations typically progress through several stages:
1. Intelligence and Case Assessment:
Initial information is assessed to determine whether the case meets the SFO’s acceptance criteria.
2. Formal Investigation:
Once opened, investigators gather evidence through:
- Compelled interviews
- Financial analysis
- Document review
- International cooperation with foreign regulators and prosecutors
3. Charging Decisions:
Prosecutors consider whether there is sufficient evidence and whether prosecution is in the public interest, following the Code for Crown Prosecutors.
4. Prosecution or Alternative Resolution:
The SFO may pursue criminal prosecution, civil recovery, or negotiated settlements such as Deferred Prosecution Agreements (“DPA”s).
Deferred Prosecution Agreements:
A DPA allows a corporate entity to avoid prosecution by agreeing to conditions such as:
- Paying financial penalties
- Cooperating with ongoing investigations
- Implementing compliance reforms
DPAs are overseen by the courts and were introduced in the UK under the Crime and Courts Act 2013.
Several multinational companies have entered into DPAs with the SFO in relation to bribery and corruption allegations.
Impact that SFO investigations can have on individuals and businesses:
An SFO investigation can have significant consequences, including:
- Reputational damage
- Financial penalties and asset recovery
- Director disqualification
- Criminal convictions and imprisonment
For corporations, early engagement with investigators and strong internal compliance systems are often critical in mitigating risk.
Major SFO Investigations (2023–2025)
Between 2023 and 2025, the SFO has pursued investigations spanning energy trading, aviation safety, legal services, construction bribery, insurance corruption, and public-sector investment fraud, demonstrating the wide scope of modern economic crime enforcement in the UK.
Glencore Corruption Case (Charges Against Former Executives – 2025)
In November 2025, the SFO charged six former Glencore employees with conspiracy to make corrupt payments linked to the company’s oil operations in West Africa. The alleged bribery scheme aimed to secure preferential access to oil contracts in countries including Nigeria, Cameroon and Ivory Coast. Prosecutors claim that fake invoices and “service fees” were used to disguise the payments.
This case follows Glencore’s 2022 corporate conviction for bribery, where the company paid hundreds of millions in penalties. The current prosecutions target individual accountability, which has been a strategic priority for the SFO.
AOG Technics Aircraft Parts Fraud (2023–Present)
The SFO opened an investigation in 2023 into AOG Technics Ltd, a UK aircraft parts supplier. The company allegedly supplied aircraft components with falsified certification documents. These parts were reportedly distributed to airlines and maintenance organisations worldwide. The suspected fraud raised serious aviation safety concerns and triggered regulatory scrutiny across the aviation sector.
United Insurance Brokers – Failure to Prevent Bribery (2025)
In April 2025, the SFO charged United Insurance Brokers Limited with failing to prevent bribery under the Bribery Act 2010. Prosecutors allege that:
- the company failed to stop intermediaries paying bribes to officials in Ecuador
- the payments were linked to securing insurance contracts in the public sector.
This prosecution is notable because corporate “failure to prevent” offences have become a key enforcement tool in UK economic crime law.
How Culbert Ellis can help
Navigating an investigation by the SFO can be complex, high-stakes, and time-sensitive. Our firm provides strategic legal advice to individuals and businesses facing allegations of fraud, bribery, or corruption.
We assist clients at every stage of an investigation, from responding to compulsory information requests under the Criminal Justice Act 1987 to representation during interviews and defence in potential prosecutions.
With a deep understanding of SFO procedures and the broader regulatory framework, we work proactively to protect our clients’ rights, manage risk, and achieve the most effective resolution possible
How To Get In Contact
To find out more or if you require assistance with these matters, speak with our Business Crime & Civil Recovery Team on +44 (0)204 600 9907 or email info@culbertellis.com.
Accurate at the time of writing. This information is provided for general information purposes only and should not be relied upon as legal advice.
