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The government have confirmed that the guidance in relation to what constitutes ‘reasonable procedures’ for the prevention of fraud is likely to be published in ‘early summer’, meaning that the new Failure to Prevent Fraud Offence would come into force by the end of the year.

See here for our article summarising the new offence

Many companies are currently considering what steps they need to take in relation to the new UK failure to prevent fraud offence (which is expected to come into force later this year or in early 2025).

By way of recap, a company will be liable for failing to prevent fraud by its associated persons (e.g.

The SFO has published its 5-year strategy document (the Strategy Document), highlighting a number of areas of focus, from international coordination with counterparts to capitalising on technology and incentivising their workforce.

This follows Director of the SFO, Nick Ephgrave’s, speech in February 2024 setting out key priorities (see our recent Investigations and Enforcement horizon


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

Following the enactment of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) last month, the UK Government has proposed in the Criminal Justice Bill (CJB) (here) to extend the scope of corporate liability for senior managers beyond certain economic offences to all UK criminal offences.

Reform of economic


Following the unprecedented levels of sanctions activity in response to Russia’s invasion of Ukraine, which has resulted in companies dealing with the most significant and complex sanctions regimes across multiple jurisdictions, authorities in the US, UK and EU are now turning their attention to enforcement of those sanctions.

Sanctions authorities have indicated that they

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


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

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

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