UK Options for Whistleblower Financial Incentive Programmes in Economic Crime Investigations

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On 13th February 2024, in a wide-ranging speech, the Director of the UK Serious Fraud Office (SFO), Nick Ephgrave, publicly stated his provisional support for financial incentives to whistleblowers in allegations of significant economic crime. This was Mr. Ephgrave’s first public speech, some six months after joining the UK’s anti-financial crime unit. Like previous Directors, having identified the challenge of investigating and prosecuting suspected fraud and corruption cases at any degree of pace, Mr. Ephgrave has embarked on reimagining the rules of the game to provide shortcuts and efficiencies. For Sir David Green, Director from 2012 to 2018, it was DPAs and an extension of the “failure to prevent” concept to all corporate financial crime – changes that have been implemented in the decade following their first mention. Sir David’s successor, Lisa Osofsky, suggested that wiretaps would improve the speed of investigations and the success rate of prosecutions. Fresh eyes on old challenges are always welcome.

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