Serious Fraud Office (SFO) Investigations

If you or your company is under investigation by the Serious Fraud Office it is essential that you contact a specialist law firm with experience of dealing with large scale, complex fraud cases.

The SFO investigates cases involving serious or complex fraud, bribery and corruption. These cases often involve high financial loss, significant economic harm, a strong public interest and may often undermine UK PLC’s commercial or financial interests in general and the City of London in particular.

Serious Fraud Office

In April 2024, Nick Ephgrave, Director of the SFO, set out the SFO’s five-year Strategy. He places emphasis on a stronger more dynamic and pragmatic organisation, one which is capable of enhancing the UK’s reputation as a ‘safe place to do business’.

The vision contained within the Strategy is to ‘specialise, collaborate and innovate to lead the fight against serious fraud, bribery and corruption’.

The criteria for the SFO taking on a case

The SFO will take on large economic crime cases. This may be any case which, in the opinion of the Director appears to involve serious or complex fraud, bribery or corruption. The Director will take into account the actual or intended harm that may be caused to the public or the reputation and integrity of the UK as an international financial centre on the economy and prosperity of the UK. He will also consider the complexity and nature of a suspected offence and whether it warrants the specialist skills, powers and capabilities of the SFO.

Not only do the SFO have a different approach to intelligence gathering during the “pre-investigation” stage with regard to Section 2 powers (see below), they also have a different approach to investigation and prosecution. A non-SFO case will be investigated by police officers and then prosecuted by lawyers. At the SFO, the Director, investigators and lawyers all work together from the outset with no separation of function.

Deferred Prosecution Agreements

The Director of the SFO may consider a deferred prosecution agreement, which is an agreement between the SFO and the organisation which could be prosecuted and which is supervised by a judge. It allows a corporate body to make reparation for criminal behaviour without the damage of a conviction. It must be in the interests of justice and the terms must be “fair, reasonable and proportionate”. These agreements are intended to be transparent.

The SFO and Assisting Offenders Legislation

A stated aim of the SFO in 2024 and beyond is to make greater use of ‘assisting offenders’ legislation. Director, Nick Ephgrave is on record as saying that the SFO not making sufficient use of the Serious Organised Crime and Police Act 2005 provisions in respect of provisions for immunity, undertakings, agreements for plea and reduction in sentence and those for sentence review (sections 71-74 SOCPA). We can advise clients on these provisions.

Section 2 Interviews and Notices

We advise clients required by the SFO to attend a compulsory interview under Section 2 of the Criminal Justice Act 1987 and those required to produce documents (Section 2 Notices). Click here to read more about Section 2 interviews.

The Olliers Team

Our fraud specialists have substantial experience of defending investigations and prosecutions instigated by the Serious Fraud Office.

We are known for our front footed, proactive approach to complex investigations. We look to establish an detailed understanding of the allegation our clients face and their alleged role in any criminality. We will seek detailed disclosure from the SFO investigators well before an interview under caution, meticulously shaping a defence strategy on behalf of our client.

Our team is headed by Matthew Claughton who over the years has been involved in a significant number of SFO and other complex fraud investigations. Team members include Matt Corn, Gareth Martin, Toby Wilbraham and Richard Cornthwaite.

Recent SFO Cases

Olliers’ recent SFO experience includes the following:

• 2022 – Representation of client under investigation in connection with alleged bribery and corruption offences connected to the activities of Amec Foster Wheeler PLC
• 2020 – Southwark Crown Court – representation of defendant in Global Forestry Investments green investment scheme
• 2019 – Representation of suspect in relation to SFO investigation into Capital Oak Pension and Henley Retirement Benefit schemes, Self-Invested Personal Pensions (SIPPS) as well as storage pod investment schemes. Investigation includes the Westminster Pension Scheme and Trafalgar Multi Asset Fund.
• 2016 – Acting for a company secretary facing allegations of conspiracy to commit fraud by false representation and conspiracy to make corrupt payments. Alleged fraud of approx. £180 million on a Belgium bank by way of falsification of receivable agreements sold on. Defendant acquitted following six-month trial.
• 2013 – SFO investigation into alleged £1.6m plot to defraud the Skills Funding Agency via football coaching apprenticeships.
• 2011 – SFO v L – Representation of director facing SFO investigation into collapse of Lexi Holdings, with alleged debts of £75m.
• 2009 – SFO V B – Defence of company director charged in relation to multimillion pound factoring fraud.

Specialist SFO Solicitors (London & Manchester)

We are ranked as a Top Tier Crime and Fraud Firm by the Legal 500 2025 as well as Chambers Directory 2025. We are a Times Top 200 law firm. We are the current Manchester Legal Awards Crime Team of the Year, an award we have won seven times since 2011.

Our Managing Director, Matthew Claughton is ranked as a Leading Individual by the Legal 500 and is a recent Legal 500 Northern Powerhouse Criminal Lawyer of the Year.  Five of our Partners are recommended Legal 500 lawyers, Matt Corn, Gareth Martin, Toby Wilbraham and Richard Cornthwaite.

If you are facing an allegation of fraud and are in need of a specialist lawyer, please contact Matthew Claughton at matthewclaughton@olliers.com or call 0161 827 7010 immediately.