Financial Crime Time - Your update from RPC: 2026 Q1

The UK government has published its Fraud Strategy for 2026–2029. The strategy sets out a new cross-government approach to tackling fraud, which remains the most prevalent crime in the UK and is estimated to cost the economy £14.4bn annually.

The strategy aims to disrupt organised fraud networks, strengthen protections for individuals and businesses, and improve the response to victims.

The strategy is structured around three pillars: Disrupt, Safeguard and Respond. Key initiatives include the creation of a new Online Crime Centre to improve intelligence sharing between law enforcement and industry, closer cooperation with the telecommunications, technology and financial services sectors to prevent fraud, and enhanced international collaboration to target overseas fraud operations.

The government also plans to expand the "Stop! Think Fraud" awareness campaign, introduce a Financial Safeguarding Scheme to help protect vulnerable individuals, and has launched Report Fraud, a new national reporting service intended to improve victim support and facilitate faster investigative responses. Report Fraud went live on 4 December 2025, marking the long-trailed replacement of Action Fraud. Report Fraud is intended to modernise the reporting process and improve the handling and assessment of fraud and cyber-crime reports.

Further details on the Fraud Strategy can be found here and the SFO's announcement relating to Report Fraud, can be found here.

The SFO is undergoing a period of leadership change following the announcement that the agency's Director, Nick Ephgrave QPM, will retire at the beginning of April 2026, halfway through his five-year tenure in the role. Under Mr Ephgrave's leadership, the SFO has commenced 12 new investigations, secured five convictions and charged over 20 defendants in fraud and bribery cases.

Graham McNulty, the current Chief Operating Officer of the SFO, will take over as Interim Director on Mr Ephgrave's retirement, until a new permanent Director is appointed.

The SFO has also announced the departure of several senior prosecutors and wider restructuring within the agency. In January 2026, it was reported that three senior prosecutors overseeing major foreign bribery investigations, including cases involving Glencore and Thales, are set to leave the SFO to join the private sector.

These changes highlight a period of organisational transition at the SFO while it continues to pursue several high-profile bribery and corruption investigations.

Further details on Mr Ephgrave's retirement and the Interim Director appointment can be found here and here.

The SFO secured a four year and eight month prison sentence against Jose Alejandro Zamora Yrala, director of AOG Technics, for orchestrating a large-scale aircraft parts fraud.

Between 2019 and 2023, AOG Technics sold more than 60,000 aircraft engine parts, valued at approximately £6.9m, supported by forged Authorised Release Certificates falsely certifying the parts as airworthy. The fraudulent activity accounted for the vast majority of the company’s revenue and exposed airlines and suppliers worldwide to serious safety risks.

The scheme came to light after an airline queried documentation linked to the parts. Safety alerts were subsequently issued by regulators including the Civil Aviation Authority, the Federal Aviation Administration, and the European Union Aviation Safety Agency, leading to aircraft groundings and widespread passenger disruption.

The SFO’s investigation resulted in Jose Alejandro Zamora Yrala pleading guilty to fraudulent trading in December 2025, bringing the case to a conclusion just over two years after it was first announced.

Further details can be found here.

The High Court has upheld an earlier ruling of the Crown Court finding that the SFO could enforce the terms of a DPA where a company fails to meet its terms.

The decision related to a DPA entered into by Güralp Systems Ltd (Güralp) in 2019, concerning charges of conspiracy to make corrupt payments and failure to prevent bribery. Güralp agreed to pay a total of approximately £2m in disgorgement of profits and penalties under the DPA. The DPA did not state a date by which payment was required to be made.

In November 2024, shortly after the term of the DPA expired, the SFO informed the Court that Güralp had failed to meet its payment obligations under the DPA and sought to enforce payment terms. On 13 January 2026, the High Court confirmed that the DPA remained enforceable by the SFO. The High Court rejected arguments advanced by Güralp that the DPA had expired before the SFO initiated breach of contract proceedings.

Güralp subsequently sought permission to appeal that ruling. However, on 10 February 2026, the High Court refused permission to appeal, leaving the SFO free to continue enforcement action for the alleged breach.

Further details can be found here.

The SFO has announced that it has discontinued its investigation into London Mining Plc and connected prosecutions of three individuals connected with the company. The investigation into London Mining had been running since 2016 and the three individuals were charged with corruption offences in June 2023. The case concerned allegations of bribery connected to mining contracts in Sierra Leone.

Following a review of material held on the SFO’s legacy disclosure platform, the agency concluded that continuing the prosecutions was no longer in the public interest and formally ended the proceedings.

The development was announced on the same day that the SFO released a statement on its ongoing review of past cases involving legacy e-discovery systems, including a review of approximately 20 cases in which not all material may have been made available for review on the SFO's systems.

Further details can be found here.

The High Court has dismissed a judicial review application by a former company director seeking to prevent the publication of his name in a judgment approving a DPA between the SFO and two companies, Bluu Solutions Ltd and Tetris-Projects Ltd.

In Robb Simms-Davies v Southwark Crown Court [2026] EWHC 337 (Admin), the Court rejected the director’s bid to prevent publication of his name in the judgment approving the DPA. The director argued that identification would cause serious harm to his reputation and professional standing.

The Court said that the principles of open justice carry particular weight in the context of DPAs, which are subject to judicial approval and published to ensure transparency. It found that the director had not demonstrated sufficiently exceptional circumstances to justify departing from the default position of open identification. Accordingly, the Court ordered that the judgment approving the DPA be published on a non-anonymised basis.

The High Court judgment can be found here.

A company director has been sentenced to two years and one month’s imprisonment for attempting to export controlled military goods without a licence.

Steven Gates sought to export military-grade thermal imaging rifle sights to Hong Kong by misdescribing them as low-value cameras in order to avoid export controls. Border Force intercepted the shipments, and a subsequent investigation uncovered further unlicensed export activity.

Mr Gates was convicted at Leeds Crown Court of offences under the Customs and Excise Management Act 1979. The case underscores the UK’s strict export control regime and increased enforcement activity in this area.

Further details can be found here.

The UK government has updated its policing reform white paper From local to national: a new model for policing, setting out detailed plans for what it describes as the most significant restructuring of policing in England and Wales in decades.

The proposals include the creation of a new National Police Service, which would consolidate existing national policing functions, including relating to serious and organised crime, counterterrorism, forensics and specialist capabilities, within a single structure, enabling local forces to focus more fully on neighbourhood policing.

The white paper also outlines reforms to the current 43-force model, the introduction of clearer national standards, enhanced performance oversight, and strengthened powers for the Home Secretary to intervene where forces are underperforming. Governance changes are envisaged, with Police and Crime Commissioners to be replaced or integrated within broader mayoral or local governance frameworks.

The government states that the reforms are intended to reduce fragmentation, improve consistency, and modernise policing in response to increasingly complex and cross-border criminal threats.

The white paper can be found here.

OFSI has announced an updated enforcement framework following its consultation on improving civil enforcement processes for financial sanctions. The changes aim to strengthen the effectiveness of sanctions enforcement while providing greater clarity and certainty for businesses.

To facilitate earlier resolution of cases, OFSI has introduced an Early Account Scheme and a Settlement Scheme, under which additional penalty discounts of up to 20% may be available where firms cooperate at an early stage.

OFSI has also indicated that it will adopt a policy of strategic prioritisation, focusing investigative resources on cases with the greatest potential impact or those addressing systemic weaknesses in high-risk sectors.

Further details can be found here and here.

OFSI has imposed a £160kpenalty on Bank of Scotland Plc for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019.

OFSI found that between 8 and 24 February 2023, the bank processed 24 payments totalling around £77k to or from a personal current account held by a person designated under the UK’s Russia sanctions regime, resulting in breaches of the prohibitions on dealing with funds and making funds available to a designated person, without a licence.

A penalty of £320k would have been imposed were it not for a 50% reduction applied following voluntary disclosure by the bank’s parent, Lloyds Banking Group.

Further details can be found here.

Transparency International's Corruption Perceptions Index 2025, has been published.

The global average score has fallen to 42 out of 100, with more than two-thirds of countries scoring below 50, indicating widespread perceived corruption worldwide. Only 31 countries have significantly improved their scores since 2012, while the remainder have stagnated or worsened, reflecting limited overall progress in tackling corruption. The UK recorded its lowest ever score of 70, falling to a ranking of 20th globally.

Further details, including country scores and rankings, can be found here.

The Corporate Criminal Offences (CCO) for the failure to prevent the facilitation of tax evasion were introduced by Part 3 of the Criminal Finances Act 2017.

Under a Freedom of Information Act (FOI) release published on 12 March 2026, HMRC confirmed that it had 43 potential CCO cases in progress as at 31 December 2025. Eleven of these were live investigations and a further 32 cases were under review. The investigations covered ten different business sectors, including software providers, waste services, accountancy and legal services and transport. According to the release, 126 opportunities had been rejected.

Notably, HMRC reported that some investigations led to the pursuit of further tax and regulatory offences, even if it had been satisfied with explanations provided and deliberate facilitation had not been established.

The release of these statistics comes after HMRC announced the first prosecution under the failure to prevent the facilitation of tax evasion offence in summer 2025, almost eight years after the legislation was first introduced.

HMRC's FOI release can be found here.