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
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
In our client alert, “The Case for Compliance: Why UK and EU Businesses Should Continue to Invest in Their Compliance Programs”, we highlighted seven reasons why, despite the US’ pause on bribery enforcement under the Foreign...more
On 6 November 2024, the UK Government published the much-anticipated guidance on the new corporate offence of failure to prevent fraud (the “Guidance”). The failure to prevent fraud offence forms part of a huge shift in the...more
It’s certainly true that the UK criminal authorities have been crying out for a shot in the arm in the form of legislative reform, but will changing the law really help the Serious Fraud Office ("SFO") achieve more corporate...more
Headlines- • The Economic Crime and Corporate Transparency Act (the “Act”) is part of a wide legislative package to prevent abuse of UK corporate structures and tackle economic crime and received Royal Assent on 26 October...more
Following mounting calls for reform of the UK's corporate criminal liability regime, the Government is expected to consult later this year on potential reforms, which are likely to include a new corporate offence of failing...more
On 6th December 2018, the trial of two Tesco executives accused of false accounting collapsed. The judge concluded that the SFO's evidence, taken at its highest, was such that a jury could not properly convict. The SFO...more