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Introduction

As anticipated in our previous horizon scan (see here), the end of 2023 has brought about significant developments in financial crime enforcement and a real focus on fraud. Looking ahead to 2024, we predict that developments affecting organisations doing business in the UK will include:

  1. a focus from organisations on fraud, in particular

A new “failure to prevent fraud” offence has been introduced as part of the Economic Crime and Corporate Transparency Act (the Act).

The Act has received Royal Assent, and although timing for implementation is unclear, it is expected that the new offence could come into force during early 2024.

This forms part of broader

Summary

There has been a recent trend of greater regulatory enforcement for international companies that “carry on a business (or part of a business) in the UK”.  We have set out in this article the relevant UK legislation and authorities that can enforce against international companies, with a particular focus on how these

Summary

As part of a new anti-corruption package announced on 3 May 2023, the European Commission has proposed a new directive (Directive) which, if implemented, would require EU member states (Member States) to meet common standards in their anti-corruption legislation.

More detail on the EU’s anti-corruption package, including the proposed new

On 19 July 2023, the UK government published proposed significant amendments to the Companies Act 2006, which would impose greater reporting requirements on large companies, including a requirement to report on material fraud. Coupled with the new failure to prevent fraud offence which we expect to come into force next year (see more here)

As anticipated in our previous blog post on predictions for 2023, this year has brought about significant developments in investigations and a real focus on fraud. Looking ahead to the second half of 2023, we predict that developments affecting UK business or those doing business in the UK will include:

  1. continued reform of corporate criminal

The UK government recently published its fraud strategy paper: Fraud Strategy: Stopping Scams and Protecting the Public.

The prevalence of fraud in the UK cannot be overstated: victims of fraud reported losing £2.35 billion in 2021 and recent research estimates fraud losses in 2021 equate to some £137 billion. The new fraud strategy has

Updated Friday 8 September 2023

The UK Government intends to introduce a new “failure to prevent fraud” offence as an amendment to its Economic Crime and Corporate Transparency Bill (the Bill). On 11 April 2023, the Home Office published a fact sheet (which was updated on 20 June 2023) and tabled an amendment to

As we enter a recession against the backdrop of ongoing geopolitical instability, we expect to see significant financial crime enforcement and investigations in 2023, including a focus on emerging areas such as ESG, cryptocurrencies, and significant developments in financial sanctions. We predict that developments in 2023 will include:

  1. a renewed focus on fraud, including further