Photo of Andrew Reeves (UK)

Andrew Reeves (UK)

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

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

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

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

Speak up and other internal investigations are on the rise (see our article here) amid increasing scrutiny from the media, public, authorities and other stakeholders of how investigations are conducted. Indeed, in higher profile matters the way in which an investigation is conducted can receive as much attention as the underlying issues.

The recent

The UK failure to prevent fraud offence has been long awaited. We are receiving a number of queries from clients about when the UK government’s “reasonable procedures” guidance is due to be published, when the offence will come into force and what they should be doing now to prepare.

In short:

  • we expect the “reasonable

This is the third article in our series breaking down the steps that organisations will need to take to put in place “reasonable procedures” to prevent fraud. Our previous posts, focusing on how to conduct effective fraud risk assessments and enhance polices and procedures, can be found here and here

The new UK failure

In the first episode of the Global Investigations Podcast Series, Andrew Reeves (Partner, Investigations, Enforcement and Compliance team, London) is joined by Ruth Cowley (Head of Disputes and Investigations, London), Keith Rosen (Head of Risk Advisory, US) and Sharon Oded (Head of Investigations, Amsterdam) to discuss the early stages of an investigation; best practice in

Introduction 

Whistleblowing is on the rise – both within organisations and to authorities. An increase in whistleblowing is positive: it shows employees feel able to speak up, allows issues to be escalated, investigated and where necessary remediated. However, the increase in whistleblowing also presents challenges for companies to ensure that they are dealing effectively and

This is the second article in our series breaking down the steps that companies will need to take to put in place “reasonable procedures” to prevent fraud. Our first post, which focussed on how to conduct effective fraud risk assessments, can be found here.  

This comes ahead of the new UK failure to