The UK’s new failure to prevent fraud offence is now in force, and it represents one of the most significant compliance challenges organisations have faced in recent years.
From 1 September 2025, large companies are automatically liable if an employee, agent or contractor commits fraud for the benefit of the organisation. This means liability doesn’t just rest with the individual—it extends to the business itself.
The only defence available is being able to prove that your organisation has “reasonable procedures” in place to prevent fraud.
What does this mean in practice?
At our recent webinar, our Managing Director, Jennifer Dunlop, outlined the key actions compliance teams should be prioritising right now. These include:
- Carrying out a fraud risk assessment – understanding where your organisation is most vulnerable.
- Identifying all “associated persons” – from employees to contractors and agents, clarity is essential.
- Reviewing and strengthening existing controls – asking whether what you have in place is genuinely fit for purpose.
- Testing reporting systems – ensuring staff know how to report concerns, and that those reports are acted upon.
Why this matters now
This isn’t a future requirement—it’s already here. The Serious Fraud Office (SFO) has signalled that it is prepared to act, and enforcement could follow quickly. Businesses that cannot demonstrate their compliance preparations risk not only regulatory action but also serious reputational damage.
How we can help
At The Compliance Office, we work with firms to design, review and test their compliance frameworks. If you are unsure whether your procedures would stand up to scrutiny, or if you simply want reassurance that you’re on the right track, we can help.
You can also watch the full webinar recording here: Failure to Prevent Fraud Webinar