For many years, the Serious Fraud Office (SFO) has been encouraging companies to self-report wrongdoing. Its success has been variable.
Since they were introduced as an alternative means of disposal of criminal proceedings, most of the SFO's Deferred Prosecution Agreements (DPAs) have involved a self-report of some kind from the corporate involved. This has led to billions of pounds of penalties paid into the UK Treasury.
The SFO has now announced a potential whistleblowing scheme through which it would pay employees to get there first.1
It is interesting to see the SFO aiming to press ahead with these plans despite being in a transitionary period under an interim Director (Graham McNulty). The SFO's previous Director, Nick Ephgrave, began his tenure with a clear statement that he wanted to introduce whistleblower incentives. He saw paying whistleblowers as having "many benefits" and forming one of "the building blocks for a much quicker and more efficient way of dealing with big cases".2
This revived an idea which last formally surfaced in 2013 (under a previous government's Serious and Organised Crime Strategy). In the interim, the Financial Conduct Authority investigated introducing financial incentives for whistleblowers but ultimately rejected the idea (apparently regarding the potential risks as too great).
After Ephgrave's speech in 2024, little more was heard for the next two years. The idea received a considerable boost in July of this year when it surfaced as...
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