He is keen for the SFO to use policing tactics to get on the front foot and effectively tackle fraud, bribery and corruption.
He says this means more dawn raids and investigations, and he is already living up to his word as the SFO conducted more dawn raids in the first three months of his tenure than they did in the previous three years.
In his words dawn raids provide “momentum to the investigation, it gets people in an interview room, you look them in the eye and start asking questions, put them under some pressure, search the house, crack the evidence, why wait?”.
What does this mean for corporates?
With the invigorated SFO prioritising serous fraud, bribery and corruption, and Ephgrave pledging to be the first to prosecute under the new provisions of the Economic Crime and Corporate Transparency Act, corporates need to be ready.
They should take steps to ensure their fraud and bribery compliance programmes are up to date and operating effectively to defend an SFO charge of failure to prevent fraud or bribery.
Also, given Ephgrave’s fondness for conducting dawn raids, corporates should make sure they are prepared. They should develop a dawn raids procedure if they do not already have one.
If they already have a process, they should refresh it to reflect the new working patterns in the post-Covid world that mean employees' home addresses could be raided, in addition to office premises.
Ben Cooper is a partner and economic crime compliance expert at TLT
