SFO anti-corruption plans set out in New York speech

If you hear 'Serious Fraud Office' and picture a distant legal body, Graham McNulty's speech at the Global Anti-Corruption, Ethics and Compliance Conference in New York on 3 June 2026 asks you to think again. In remarks later published by the UK Government on GOV.UK, the SFO's interim director argued that big fraud and bribery cases are not side issues for specialists. They are public harms that cross borders, weaken trust and can touch everything from government contracts to air safety. For us, the useful way into this story is not the conference setting. It is the question underneath it. What does the SFO actually do, why is it talking so much about company cooperation, and why should you care if you are not a lawyer or compliance officer? Once you strip back the official phrasing, this was a speech about power: who gets to abuse it, and how the state says it plans to respond.

The SFO is the UK's specialist agency for the most serious fraud, bribery and corruption cases, and McNulty spent part of the speech explaining why those cases can move slowly. SFO investigations often involve money moving through several countries, huge volumes of documents, and defendants with far greater resources than the public body trying to prosecute them. He said an average case can involve around 5 million documents, with trials that can last up to six months and losses that reach tens or hundreds of millions of pounds. **What this means:** when people ask why a white-collar case seems to take years, the answer is not always simple delay or lack of effort. These cases are built by mixed teams of investigators, lawyers, forensic accountants and digital experts working together from the start. That matters because the SFO's model is meant to follow a case from first intelligence through to prosecution and asset recovery, rather than treating each stage as somebody else's job.

McNulty's first big promise was aimed at what he called responsible corporates. His example was the newly agreed Deferred Prosecution Agreement, or DPA, with defence supplier Ultra Electronics. According to the SFO, the company accepted accountability for failing to prevent bribery linked to three public sector contracts pursued through agents, and it must pay a £10 million financial penalty plus £4.8 million in SFO costs. The backstory matters here. Ultra self-reported in 2018, was invited into DPA talks in 2021, then saw those talks collapse in 2022 after the SFO said new information about conduct in Oman changed the picture. Negotiations only restarted after major changes in the company's ownership, structure and leadership. **What this means:** a DPA is not a company simply walking away. It is a court-approved deal that pauses prosecution on conditions, and the speech made clear that the SFO sees genuine cooperation as the price of entry.

This is why McNulty spent so much time on the SFO's revised corporate cooperation guidance. The message to boardrooms is direct: if a company spots wrongdoing, tells the SFO quickly and cooperates fully, the office says it will usually invite that company to DPA negotiations unless there are exceptional reasons not to. The guidance, first issued last year, also promises contact within 48 business hours of a self-report, regular updates, a decision within six months on whether to open an investigation, and a target of finishing DPA negotiations within six months of an invitation. That sounds technical, but the public interest point is easy to grasp. Companies are more likely to report misconduct if they believe the process will be clear and not drag on without end. **Fact-check on the jargon:** a near-guarantee of an invitation to talks is not the same as a guarantee of leniency. McNulty was equally blunt that the SFO will walk away from negotiations and prosecute if a business only cooperates halfway or tries to control the story.

The second promise was tougher. McNulty wants the SFO to stop looking like a body that waits for tips and referrals, and start looking more like an agency that finds wrongdoing for itself. He said the UK Government has put millions of pounds into new intelligence capacity, including an enterprise system designed to pull together data from different sources and spot links across cases. In plain English, that means the SFO wants to join dots earlier and rely less on companies volunteering bad news. He paired that with a call for more use of surveillance. One of the sharpest lines in the speech was his complaint that economic crime can be treated too 'gentlemanly', as if a sharp suit should earn more patience than a street-level offender would get. **What this means:** the SFO is trying to reframe fraud and bribery as serious crime in the fullest sense, not as respectable misbehaviour. That is why one of the speech's quiet warnings was simple: not self-reporting is becoming a riskier bet.

The same thinking sits behind his push for whistleblower incentives. McNulty argued that insiders can cut through years of document trawling by telling investigators what happened, when it happened, who was involved and where the evidence sits. In the speech, he pointed to a striking number: more than 700 UK nationals used US whistleblower reward programmes between 2012 and 2023. His case is that valuable intelligence is already leaving the UK, because American schemes offer something Britain does not. There is an obvious civics lesson here. Whistleblower policy is not just about reward money; it is about how much a state values inside information when powerful organisations break rules. The UK Government has asked Jonathan Fisher KC to consider the issue in the second part of his review, expected later in 2026. **What this means:** if ministers back change, the way major fraud cases begin could shift quite quickly.

McNulty also pointed to new legal tools, especially the Economic Crime and Corporate Transparency Act. For readers new to this area, one of the biggest changes is the failure to prevent fraud offence. It means large organisations can face criminal liability if an associated person commits fraud intending to benefit the organisation, so long as there is a UK link. He also highlighted the 'senior manager' test, which makes it easier than before to pin corporate criminal responsibility on a company when wrongdoing sits high enough in the chain of command. **What this means:** anti-corruption policy is not only about catching people after the damage is done. It is also about forcing firms to build proper prevention systems before a scandal erupts. If the SFO uses these powers as aggressively as McNulty suggested, compliance stops being a box-ticking exercise and becomes a question of whether a company's culture can stand up in court.

The final part of the speech was international. McNulty stressed close work with the US Department of Justice and other American agencies, and he pointed to the anti-corruption prosecutorial taskforce created with France's PNF and Switzerland's Office of the Attorney General. That matters because bribery, fraud and illicit finance rarely stay inside one jurisdiction. Evidence sits abroad, funds move quickly, and prosecutors have to decide who is best placed to act. He even suggested that where a case has a UK link but does not fit current US enforcement priorities, the SFO will look actively at taking it on. His example was the SFO's AOG Technics case. According to the speech, between 2019 and 2023 the company falsified paperwork linked to more than 60,000 aircraft parts, and safety alerts later grounded hundreds of planes in the UK and beyond; the SFO said it secured a conviction at the end of 2025. **Why it matters:** when corruption distorts public contracts, when fraud infects supply chains, or when companies hide behind borders, ordinary people absorb the risk. That is the point worth carrying away from all the official language. The SFO wants more self-reporting, faster resolutions and tougher enforcement, but the real test is whether those promises make the public safer and the system fairer.