Photo of Neil O’May (UK)

Neil O’May (UK)

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 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

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