COMPLIANCE
From Legal Compliance to Compliance Culture: The UK ' s New Failure to Prevent Fraud Regime
Dr Johannes Dittrich Elly Proudlock
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A New Era of Corporate Accountability On 1 September 2025, the UK introduced a criminal offence that reshapes corporate liability for fraud – like the UK Bribery Act did for corruption. The " failure to prevent fraud "( FTPF) offence under the Economic Crime and Corporate Transparency Act 2023 imposes strict corporate criminal liability where any“ associated person " commits fraud intending to benefit the organisation or its clients – unless the organisation can demonstrate it had reasonable fraud prevention procedures in place.“ Associated person” is broadly defined to capture a wide range of third parties connected with the organisation, as explained further below.