Shifting geopolitical dynamics have seen a wave of changes across the international investigations and enforcement landscape. In this edition, we focus on some of the most significant of these changes – from the issue of new cooperation guidelines by the Serious Fraud Office (SFO) to the abandonment by the Financial Conduct Authority (
Countdown to Compliance: five key priorities for those preparing for the UK’s New Failure to Prevent Fraud Offence
With under two weeks to go until the new UK failure to prevent fraud offence comes into force, this blog discusses the priority actions companies can take in preparation.
On 1 September 2025, the UK’s new “Failure to Prevent Fraud” (FtPF) offence will come into force, reshaping corporate liability for fraud and effectively
FTPF: Considerations for In-house Lawyers
The new failure to prevent fraud (FtPF) offence, which will come into effect on 1 September 2025, poses some potential challenges for an in-house legal team (Legal Team) including anticipating and mitigating associated risks such as:
(1) the risk that a member of the Legal Team commits an underlying fraud offence
New co-operation guidance issued by the SFO
The SFO’s new cooperation guidance SFO Corporate Guidance – GOV.UK (published on 24 April) updates the SFO’s original cooperation guidance published in 2019 and comes ahead of the new failure to prevent fraud offence coming into force in September 2025 (see here: Failure to prevent fraud: What should you be doing before September? | Global
New SFO Corporate Guidance
On 24 April 2025, the Serious Fraud Office (SFO) published new guidance for firms about self-reporting, co-operation and Deferred Prosecution Agreements (DPAs) – a timely development in light of the failure to prevent fraud offence coming into force on 1 September 2025, which the SFO has recently said it is looking
Failure to prevent fraud: what should you be doing before September?
With less than five months to go until the new UK failure to prevent fraud offence comes into force on 1 September 2025, many organisations are conducting risk assessments and enhancing anti-fraud policies and procedures with a view to preventing fraud and providing themselves with a defence should this be necessary.
The new offence will
Failure to Prevent Fraud – Risk Assessments
Introduction
On 6 November 2024 the UK government published its long-anticipated guidance on the failure to prevent fraud offence (the Guidance).
The new offence will come into force in September 2025. It will apply both to UK and to non-UK organisations, where there is some nexus to the UK. The only defence for an
Failure to prevent fraud guidance on reasonable procedures: a first look
On 6 November 2024 the UK government published its long-awaited guidance (the Guidance) on the new offence of failure to prevent fraud (here) and confirmed the offence will be in force from 1 September 2025.
Under the new offence an organisation (whether or not it is a UK organisation) may be criminally
Failure to prevent fraud: UK government today publishes important guidance on the new offence
The UK government has today published its long-awaited guidance to organisations on the new offence of failure to prevent fraud (here) and confirmed the offence will be in force from 1 September 2025.
Under the new offence an organisation (whether or not it is a UK organisation) may be criminally liable where an
Failure to prevent fraud: five key steps for regulated financial services firms
The new failure to prevent fraud offence is due to come into force during 2025. In broad terms, in respect of the financial services community, it will mean that regulated firms of a certain size could be at risk in the event that fraud is committed for their benefit or the benefit of their clients