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
The FCA and OFSI clamp down on UK sanctions enforcement
The resolution of two sanctions-related investigations over the last month by both the Financial Conduct Authority (FCA) and the Office of Financial Sanctions Implementation (OFSI) could signal the start of the anticipated increase in UK enforcement in respect of failings relating to financial sanctions systems and controls (in the case of
New briefing note – Insights from the FRC Annual Enforcement Review 2024
Following on from the UK Financial Reporting Council (FRC) publishing its plan and budget for 2024-25 earlier this year, the King’s Speech in July signalled that the long-awaited transition of the FRC to a new Audit, Reporting and Governance Authority could now be firmly on the horizon. In an effort to strengthen audit
Indirect Governance and Sanctions Risk Exposure in Decentralised Finance (DeFi)
As the FinTech industry continues to experience increased regulation across multiple jurisdictions, the focus of sanctions authorities is turning to decentralised finance (DeFi) and those operating in the crypto space. In the US we have seen a wave of recent enforcement actions against participants in the crypto sector and strong statements from authorities
Fit for purpose? The UK’s Treasury Committee scrutinises UK sanctions
- Economic sanctions are a critical weapon in resisting Russia’s war against Ukraine.
- Despite its own production of
New briefing note: FRC enforcement – five key themes for 2024
With a record number of enforcement cases resolved in recent years, the Financial Reporting Council (FRC) is continuing to show its determination to hold firms and individuals to account for serious accounting and audit failures. In our latest briefing, we set out five key themes for relevant firms and individuals to be aware