The Crime and Policing Bill 2025 received Royal Assent on 29 April 2026, meaning organisations will be criminally liable where a senior manager commits any criminal offence in the UK while acting within their actual or apparent authority. This replaces and broadens the changes made by the Economic Crime and Corporate Transparency Act 2023 (which applied senior manager liability to specific economic crime offences).

Four key implications businesses should consider as this legislation advances:

  1. Companies will be much more likely to face prosecution (or at least investigation) in the event of suspected criminality.
  2. Need to conduct risk assessments and ensure compliance programmes are effective.
  3. Need to map and train senior management.
  4. Companies should expect much greater scrutiny of compliance programmes and internal investigations from financing parties, auditors and acquirers.

For more information see our article here.

Please let us know if you would like to discuss this very significant development.