In the next instalment of our global horizon series (first instalment available here), our team observes a growing trend of increased international collaboration between regulators in different jurisdictions despite wider geopolitical tensions.
Europe
The European Public Prosecutor’s Office (EPPO), the independent public prosecution office of the European Union has become increasingly active. It is
Authorised Push Payment (APP) fraud continues to be one of the most damaging and rapidly evolving forms of financial crime in the UK. In these scams, victims are tricked into willingly transferring money to fraudsters under the guise of legitimate transactions. Unlike unauthorised fraud, where criminals gain access to accounts without consent, APP
In the first instalment of our global horizon scanner series, our team consider the growing trend of increased regulatory enforcement relating to anti-money laundering.
Although there is some variation in these priorities between regulators, we have seen an increase across the board in enforcement actions. We take a look at jurisdictions where there have been
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 (
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
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
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
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
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
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