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:
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
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