Nick Ephgrave’s SFO: reform, results and uncertainty

Serious Fraud Office (SFO) Director Nick Ephgrave’s retirement announcement on January 15 — made halfway through his five-year term and the day after a series of raids and arrests linked to a fraud and bribery investigation into the past management of Home REIT — took many by surprise.

It has understandably prompted observers to review his progress and achievements at the agency and to question what the future now holds for the SFO, given debates in the past about whether it was fit for purpose and whether its function would sit better elsewhere.

Nick Ephgrave was an unexpected successor to Lisa Osofsky back in 2023, primarily due to his background as a career police officer. His status as the first non-lawyer to hold the post of SFO Director was controversial. At the time, there was even suspicion that his appointment may have been to ensure an orderly merger into the National Crime Agency (NCA), an idea that had never entirely gone away since it was known to have been supported by Theresa May when she was Home Secretary as early as 2011.

Over the last two and a half years, Nick has surprised critics and brought new pride and direction to the SFO. This comes after a period of decline that hit its lowest in July 2022, when judicial reviews were published on the SFO’s management of two separate cases. These reviews revealed recurring internal issues such as limited resources, insufficient supervision, problems with legal disclosure processes, and an unhealthy organisational culture. Many believe that, at least from the outside, it has looked like he was doing a good job of getting things back on track. 

A vision for transformation

In his first speech as Director in February 2024, Ephgrave set out an ambitious vision and road map for the organisation. He was unapologetic about his background as "a law enforcer" rather than a lawyer and described himself as having a "visceral reaction" to fraud and corporate misconduct, dispelling any suggestion that fraud is a victimless crime. He committed to bringing perpetrators “to justice securely and quickly.”

Pledges included making SFO cases “faster” through rigorous case reviews, introducing "technology-assisted review" using machine learning for disclosure and significantly increasing enforcement activity — all of which have seen some follow-through. Even at the time of the speech, he could already proudly boast of more dawn raids in his first three months than in the previous three years and he was astute in courting publicity for such when he invited the media to oversee a raid operation in real time. He showed himself to have a modern touch and to be very serious about improving the SFO's reputation and impact on the public.

His approach brought a refreshing directness to the role. Where previous directors might have emphasised legal technicalities, Ephgrave spoke plainly about the human cost of fraud, highlighting cases affecting 40,000 individuals and pensioners losing life savings. This victim-focused narrative resonated with the public and helped rebuild confidence in the agency's mission.

A lasting legacy on whistleblowing

Perhaps his strongest and potentially lasting contribution will be his advocacy for financial incentives for whistleblowers, drawing on the experience of US enforcement agencies. His endorsement of this model has piqued the support of some regulators and politicians, and the UK Anti-Corruption Strategy 2025 published in December includes a commitment to assess the feasibility of introducing financial incentive schemes and support for individuals reporting economic crime.

There are many legal and practical obstacles that mean this is perhaps not the silver bullet he is clearly convinced it is – even in the US it is more successful in the civil and regulatory arena than in the criminal sphere – but the topic is definitely firmly on the agenda thanks to his campaigning. His willingness to champion controversial reforms demonstrated a boldness that had been lacking in previous leadership.

Timing and uncertainty

Ephgrave’s retirement comes just as the SFO is heading into an important year, with more trials scheduled and investigations and prosecutions underway than the SFO has had for many years, including trials this year related to Petrofac, Patisserie Valerie, and Buy2Let Cars. Its report card will be judged by several different stakeholders on the outcomes of these assignments.

However, an early retirement gift and a big tick on that report card came the day after his retirement was announced, with the conviction of three former directors of Ethical Forestry Limited who pleaded guilty to a £70 million investment fraud scheme following an SFO investigation. The trial that had been listed for February will now be a sentencing hearing in May.

What lies ahead?

Speculation will now be rife about where Nick's departure leaves the SFO. We know an interim head is expected to be appointed as soon as possible to steady the ship and oversee its important schedule in 2026, but there can be little doubt that it remains vulnerable to a merger, perhaps even more so now than before given the wider review going on of how to tackle the challenges in the justice system.

The Secretary of State for Justice David Lammy and Justice Minister Sarah Sackman are under pressure to speed up justice and do more with less. A merger of the SFO into the NCA could be a headline-grabbing move that would be seen as radical and bold. However, it was certainly not in any election manifesto, and without a clear vision and purpose we have seen such mergers in the past result in periods of institutional inertia, with limited upside and resulting in little more than moving chairs around the deck.

The timing of Ephgrave's departure raises questions about whether the momentum he built can be sustained. His successor will inherit an agency with renewed purpose but also one facing significant operational pressures and an uncertain future within the broader justice system architecture.

Although his tenure has been short, Nick leaves the agency stronger, more focused and more efficient than he found it. Nonetheless, many will wish he could have stayed longer to see his strategy bear more fruit and to preserve the long-term health of the organisation he has led.

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