Information Commissioner's Office

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You are here: BAILII >> Databases >> Information Commissioner's Office >> Serious Fraud Office (Central government) [2024] UKICO 284058 (14 May 2024)
URL: http://www.bailii.org/uk/cases/UKICO/2024/284058.html
Cite as: [2024] UKICO 284058

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Serious Fraud Office

The complainant requested information on the cost of the investigation by the Serious Fraud Office (the ‘SFO’) into Eurasian Natural Resources Corporation Ltd (‘ENRC’). The SFO refused to disclose this information, citing the exemption provided by section 31 (law enforcement) of FOIA. Specifically, it relied on subsections 31(1)(a) – the prevention or detection of crime, 31(1)(b) – the apprehension or prosecution of offenders and 31(1)(c) – the administration of justice, to withhold the requested information. During the course of the Commissioner’s investigation, the SFO additionally relied on section 21 (information accessible to applicant by other means) and section 22 of FOIA (information intended for future publication) for part 3 of the request. The Commissioner’s decision is that the SFO was entitled to rely on sections 31(1)(a), (b) and (c) of FOIA to refuse to disclose the withheld information. As he has found section 31(1) to apply to all parts of the request, he has not deemed it necessary to consider the SFO’s reliance on sections 21 and 22 of FOIA. The Commissioner requires no steps to be taken as a result of this decision.

FOI 31: Complaint not upheld

Decision notice: 284058