Data Driven Compliance: The Failure to Prevent Fraud Offense: Insights for US General Counsels with Mike DeBernardis
Data Driven Compliance – James Tillen on the Importance of Cross-Functional Collaboration in Complying with the FTPF Offense
Everything Compliance: Episode 158, The No to Corruption in Ukraine Edition
Data Driven Compliance: Understanding the UK’s New Failure to Prevent Fraud Offense with Sam Tate
1 September 2025 marks the day that the new strict liability corporate criminal offence of failure to prevent fraud comes into effect. From today onwards, corporate entities can be held criminally liable for failing to...more
On 11 August 2025, HM Revenue & Customs ("HMRC") initiated its first corporate prosecution under the failure to prevent the facilitation of tax evasion offence, which was introduced by the Criminal Finances Act 2017. Bennett...more
On 18 August 2025, the UK’s Crown Prosecution Service (CPS) and the Serious Fraud Office (SFO) announced the updated version of the joint guidance in relation to the prosecution of corporate entities (the “Guidance”). The...more
The new strict liability corporate criminal offence of Failure to Prevent Fraud (FTPF) comes into effect in England and Wales on 1 September 2025. ...more
Shakespeare’s observation that the “past is prologue” certainly applies to corporate criminal liability in the UK and France, as these jurisdictions embrace with gusto corporate prosecutions akin to those pursued in the US...more
Introduction - As part of a global crackdown on tax evasion, the Criminal Finances Act 2017 (the Act) introduced a new offence. From 30 September 2017, an organisation commits a criminal offence if an employee or...more