Photo of Thomas Hubbard (UK)

Thomas Hubbard (UK)

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

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

On Tuesday 16 April 2024, please join us for a webinar where our team from across EMEA will discuss the key recent and upcoming trends in financial crime legislation and regulatory enforcement in the EU, UK and Singapore.

This webinar will highlight important changes to anti-money laundering regulation and wider financial crime legislation in the


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

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

The UK government recently published its fraud strategy paper: Fraud Strategy: Stopping Scams and Protecting the Public.

The prevalence of fraud in the UK cannot be overstated: victims of fraud reported losing £2.35 billion in 2021 and recent research estimates fraud losses in 2021 equate to some £137 billion. The new fraud strategy has

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

As we enter a recession against the backdrop of ongoing geopolitical instability, we expect to see significant financial crime enforcement and investigations in 2023, including a focus on emerging areas such as ESG, cryptocurrencies, and significant developments in financial sanctions. We predict that developments in 2023 will include:

  1. a renewed focus on fraud, including further