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 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
Information sharing by regulated firms
On 4 October 2024, the Department for Business & Trade published guidance (the Guidance) on the information sharing measures in the Economic Crime and Corporate Transparency Act 2023 (ECCTA).
The purpose of the Guidance is to support firms operating in the “regulated sector” within Schedule 9 of
Speak up and other internal investigations are on the rise (see our article here) amid increasing scrutiny from the media, public, authorities and other stakeholders of how investigations are conducted. Indeed, in higher profile matters the way in which an investigation is conducted can receive as much attention as the underlying issues.
The recent
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
This is the second article in our series breaking down the steps that companies will need to take to put in place “reasonable procedures” to prevent fraud. Our first post, which focussed on how to conduct effective fraud risk assessments, can be found here.
This comes ahead of the new UK failure to
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