Eye on Economic Crime: Transformation of the UK Fraud Prevention Landscape
We detail below some recent developments which track the transformation of the UK's fraud prevention landscape and what this means for companies.
Whistleblower Incentivisation: A Transformative Tool
On 4 June 2025, Lucy Rigby, the UK Solicitor General, signalled robust support for a suite of new measures aimed at strengthening the Serious Fraud Office’s ("SFO") capacity to investigate and prosecute complex financial crime. Central to these proposals is the introduction of financial incentives for whistleblowers - a move that could mark a significant shift in the UK’s approach to economic crime enforcement and align it more closely with established US practices.
This follows sustained advocacy from SFO Director Nick Ephgrave, who has called for the UK to adopt a US-style system where individuals who provide actionable intelligence to prosecutors can receive a share of the proceeds recovered from successful cases. See our previous updates on this here and here.
Ephgrave has argued that such a scheme would not only enhance the SFO’s ability to direct its resources more strategically but also stem the “brain drain” of informants who currently take valuable information to US authorities, attracted by the prospect of financial rewards. The US model, particularly under the Foreign Corrupt Practices Act, has demonstrated the effectiveness of incentivising whistleblowers, both domestically and internationally, in uncovering and prosecuting complex fraud and bribery schemes (read our latest alert from the US perspective here).
Separately, the UK tax authority HMRC, recently announced that it shall launch a new financial incentivisation scheme along the very same lines, based upon the US and Canadian models. HMRC's scheme comes in the wake of the Chancellor’s Autumn Budget, which set out the Government’s commitment to closing the tax gap. HMRC already pays informers on a discretionary basis but the lack of transparency of the incumbent system will now be replaced by a clearer scheme “with informants rewarded with a percentage of any tax taken as a result of their actions”. Whilst a date for the scheme's launch has not been provided by the Government yet, it is very possible that this announcement will spur the SFO to take similar steps soon too.
Broader Legislative and Enforcement Context
The push for whistleblower incentives comes amid wider efforts to enhance the SFO’s powers and resources. Lawmakers have emphasised the need for increased funding and support for the SFO, particularly in managing the vast disclosure obligations that accompany large-scale investigations. There is also concern over the lack of enforcement in foreign bribery cases involving UK small and medium-sized enterprises, with calls for the SFO to take a more proactive role in prosecuting such offences and for the Government to ensure adequate resourcing for these efforts.
In response to this, the Government has committed to a funding boost to support the SFO's strategic vision. UK Attorney General Lord Hermer KC welcomes the additional £8 million of investment to "tackle serious economic crime". The extra funding will enable the SFO to expand its investigative reach and use of technology to assist with disclosure. This is in addition to the £9.3 million funding announced in the Budget, totalling £97.64 million across the next three years.
In terms of enforcement, the SFO appears committed to developing its international collaborative efforts. Further to our reporting on the SFO's new taskforce with France’s Parquet National Financier and the Office of the Attorney General of Switzerland, the SFO announced in late June 2025 that it shall join the International Anti-Corruption Coordination Centre ("IACCC"), strengthening the UK’s ability to tackle grand corruption and illicit finance across borders. The IACCC brings together specialist law enforcement officers from agencies around the world so this move will boost the SFO’s capacity to gather intelligence and evidence.
The Onus on Technology and Social Media Platforms
In parallel, there is growing consensus that technology and social media platforms must play a more active role in fraud prevention and victim compensation. Recent regulatory changes under the Online Safety Act have imposed new obligations on online platforms to remove fraudulent material and provide reporting channels, but lawmakers argue that further measures may be necessary if these prove insufficient. There is increasing pressure for technology firms to implement robust identity verification, enhance monitoring, and contribute financially to compensating victims of fraud, reflecting a broader shift towards shared responsibility across the fraud prevention ecosystem.
Implications for Companies
These developments signal a move towards a more proactive, collaborative, and resource-intensive approach to tackling economic crime in the UK. Companies should closely monitor the progress of whistleblower incentivisation proposals and consider the potential impact on their compliance frameworks, particularly in light of the new ‘failure to prevent fraud’ offence under the Economic Crime and Corporate Transparency Act 2023, in force from September 2025 – see our previous alerts here and here for more information.
