On 13 February 2024, Nick Ephgrave gave his first public speech as Director of the UK’s Serious Fraud Office (SFO).

Mr Ephgrave celebrated the SFO’s recent victories, the biggest ever deferred prosecution agreement with Airbus, worth €1bn, the £280m prosecution of Glencore and the prosecution of a former solicitor for tipping off his client about a money laundering investigation.

However, he recognised there are areas for serious improvement and vowed that under his leadership, the SFO will be bolder, more pragmatic, more proactive and ultimately process cases much quicker. He also refers with excitement to the great new tools for the SFO in the Economic Crime and Corporate Transparency Act 2023 and states his ambition to be the first to prosecute those offences.

Unlike the previous SFO Directors, Mr Ephgrave is not a lawyer, he’s a law enforcer with 30 years’ experience and wants to bring more police tactics into the SFO’s operations. This, he says, “means more dawn raids and swifter action – we have already gone through more front doors in the last three months than in the last three years. Why? This provides momentum to the investigation, it gets people in an interview room, you look them in the eye and start asking questions, put them under some pressure, search the house, crack the evidence, why wait?

As Mr Ephgrave says, we have already seen more dawn raids in the last three months than in the last three years and as this is a key plank of his vision of the SFO being bolder and more proactive, so he promises, and we expect to see, many more dawn raids.

So “why wait?” Now is the time to dust off your dawn raids policy and train your staff!

How TLT can help

Our experts help you:

  • Plan your dawn raid response, from preparation for first responders through to drafting detailed dawn raid manuals.
  • Practice your response, with informative training sessions, interactive simulated raids and realistic in-person mock raids.
  • Be prepared, with expert advisors on hand and ready to help should a regulator make an unannounced inspection at your premises, or the homes of individual employees. Read more about our dawn raid services here.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at February 2024. Specific advice should be sought for specific cases. For more information see our terms & conditions.

Date published

19 February 2024

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