Business ethics news: SFO whistleblower rewards, a new self-report route and six Libor convictions quashed (17 October 2026)

Government consults on paying whistleblowers a share of SFO corporate penalties

A consultation published on 12 October seeks views on the whistleblowing framework in the Employment Rights Act 1996 and on a proposed Serious Fraud Office scheme to pay financial rewards to people who report economic crime. It closes at 23:59 on 8 January 2027. The proposal follows recommendations in Part 2 of Jonathan Fisher KC's Independent Review.

Under the proposed design, information must be "significant and original" and must lead to a successful outcome against a company, such as a conviction or a Deferred Prosecution Agreement. Rewards would be a percentage of the company's fine or penalty, paid only once a case has concluded and appeal rights are exhausted. Claimants would not need to be workers, and the paper asks whether rewards should be uncapped, as most schemes are. It cites a typical range of 10% to 30% overseas and HMRC's Strengthened Reward Scheme, which can pay up to 30% of tax collected where at least £1.5 million is recovered. The paper also floats new offences for knowingly false reports and for harassing or intimidating whistleblowers.

For employers, the bigger question is Chapter 8: whether to keep voluntary guidance or bring in a statutory duty to have whistleblowing procedures, a policy and follow-up, broadly modelled on Ireland's rules for employers with 50 or more staff (acknowledge within seven days, feedback within three months). The government's initial view is against creating a central whistleblowing body, but it asks for views.

Source: GOV.UK, A consultation on whistleblowing, 12 October 2026.

SFO adds a direct line to its General Counsel before a corporate self-report

On 13 October the Serious Fraud Office updated its Corporate Cooperation Guidance so that a company's lawyers can discuss a possible self-report with Matthew Wagstaff, its Director of Legal Services and General Counsel, through a dedicated address, GeneralCounsel@sfo.gov.uk, before committing to a formal report. The change followed practitioner feedback since the guidance was first revised in April 2025.

The core offer is unchanged: companies that report promptly and cooperate fully will, barring exceptional circumstances, be invited to negotiate a Deferred Prosecution Agreement. The SFO commits to make contact within 48 business hours of a self-report and to decide whether to open an investigation within six months. The update clarifies that companies should take a proportionate, risk-based approach to establishing the extent of offending, and that the six-month period for concluding DPA negotiations runs from when an invitation to negotiate is accepted.

Separately, the Attorney General opened applications for a new SFO Director on 7 October. The post is a five-year fixed term, and applications close at 23:55 on Friday 30 October.

Source: Serious Fraud Office, 13 October 2026; Attorney General's Office, 7 October 2026.

Court of Appeal quashes six more Libor and Euribor convictions; FCA revokes four bans

On 7 October the Court of Appeal overturned the convictions of Jonathan Mathew, Jay Merchant, Alex Pabon, Philippe Moryoussef and Colin Bermingham. The SFO did not oppose those appeals, which followed the Supreme Court's 2025 ruling that the jury directions in the Tom Hayes and Carlo Palombo trials were wrong. On 9 October the court also quashed the conviction of Christian Bittar, who had pleaded guilty to conspiracy to defraud; the SFO said it had argued for a different outcome.

On 16 October the FCA said it had revoked its bans on Bermingham, Moryoussef, Mathew and Bittar, removed the related Final Notices, and would take no further action against them on this matter, because the convictions were the basis for its action.

For compliance teams, the episode is a reminder that how a court defines dishonesty in a market practice case decides the outcome, not just what traders did.

Source: Serious Fraud Office, updated 7 and 9 October 2026; FCA, 16 October 2026.

FCA orders an independent review of how it treated a whistleblower who died

In a blog on 6 October, FCA General Counsel Stephen Braviner Roman said the regulator had asked Lea Paterson, a new independent non-executive director, to review how it interacted with whistleblower Simon Andriesz, who had died the week before after years of contact with the FCA. Lessons and how the FCA will act on them are due to be shared early next year.

The FCA said whistleblowing reports rose 22% last year. It gave feedback on each of the 1,252 reports it closed; 42% led to direct action to manage or reduce harm and a further 53% informed wider work.

Source: FCA, 6 October 2026.

ISSB to launch its nature disclosure proposals at COP17 on 22 October

The ISSB will mark the launch of an exposure draft proposing a Practice Statement on nature-related disclosures with a webinar at the UN biodiversity conference, COP17, on Thursday 22 October. The consultation runs for 120 days to 19 February 2027. The Practice Statement is meant to help companies apply IFRS S1 to nature-related risks and opportunities and draws on the TNFD's work.

A Practice Statement would sit alongside IFRS S1 and S2 rather than change their requirements, so it adds guidance, not a new mandatory standard.

Source: IFRS Foundation, 6 October 2026.

What this means

If your company might face a fraud or bribery issue, the SFO now offers an informal first conversation before a self-report, and a future reward scheme would give insiders a cash reason to go to the SFO first. Both point the same way: an internal speak-up route that staff trust, and a quick decision on self-reporting, matter more than they did a month ago. Responses to the whistleblowing consultation are due by 8 January 2027.