Partner Lucy Blake Discusses the SFO’s Plan to Incentivise Witness Cooperation

London-based Investigations, Compliance, and Defense Partner Lucy Blake provided commentary to Edward Fennell's Legal Diary about the Serious Fraud Office’s intention to incentivise witness corporation. 

Lucy describes the recent publication of the SFO Strategy 2024-2029, coming “hot on the heels” off the US Department of Justice launching its own cooperating witness incentivisation programme. She observes that the strategy makes clear the SFO’s commitment to “explore incentivisation options for whistleblowers, working with partners in the UK and abroad”.

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“SFO Director, Nick Ephgrave QPM, has previously expressed his desire to make greater use of cooperating witnesses and whistleblowers. The Serious Organised Crime and Police Act 2005 does provide scope for relief through grants of immunity and the conclusion of restricted use undertakings – the British analogue of non-prosecution agreements. Whilst these measures are currently not widely used by UK law enforcement, the SFO’s recent announcement may signal greater alignment with its key partners.”

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Partner Lucy Blake Discusses the SFO’s Plan to Incentivise Witness Cooperation

London-based Investigations, Compliance, and Defense Partner Lucy Blake provided commentary to Edward Fennell's Legal Diary about the Serious Fraud Office’s intention to incentivise witness corporation. 

Lucy describes the recent publication of the SFO Strategy 2024-2029, coming “hot on the heels” off the US Department of Justice launching its own cooperating witness incentivisation programme. She observes that the strategy makes clear the SFO’s commitment to “explore incentivisation options for whistleblowers, working with partners in the UK and abroad”.

Read More

“SFO Director, Nick Ephgrave QPM, has previously expressed his desire to make greater use of cooperating witnesses and whistleblowers. The Serious Organised Crime and Police Act 2005 does provide scope for relief through grants of immunity and the conclusion of restricted use undertakings – the British analogue of non-prosecution agreements. Whilst these measures are currently not widely used by UK law enforcement, the SFO’s recent announcement may signal greater alignment with its key partners.”

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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