Speaking on Tuesday to a House of Commons Parliamentary Committee David Green, the Director of the Serious Fraud Office, underscored that significant progress is has been made in coming up with a new funding model for the SFO and that the SFO should never turn down an investigation because it does not have enough money.

Critics repeatedly point to the SFO’s limited annual budget from the Treasury highlighting the disparity between the tough talk and the resources to deploy to deliver on it.

We know from our conversations with the new Director that the subject of funding of the SFO is a matter which is extremely important.

In our discussions with the Director he also relayed his view that the SFO should not be prevented from investigating cases for want of funding and pointed to the LIBOR investigation as a case in point.

As we have previously highlighted, funding for this investigation is being provided to the SFO in addition to the departments annual budget. It is understood at the present time approximately 40 people within the SFO (headcount c.300) are working on LIBOR (or close to 15% of its employees).

While, the new funding model has not yet been finalised and revealed we anticipate that it will be a combination of the annual budget, the ability to request specific funding for specific cases and an increased focus on using the UK’s draconian money laundering laws to fund the agency.

The clear message though is that focusing on the annual budget and calculating the likely enforcement risk in relation to Serious Fraud, is likely to be a risky business.