Jenner & Block Hosted Workshop with Grant Thornton UK on “Breaking Down the New Failure to Prevent Fraud Offence”

Jenner & Block and Grant Thornton UK hosted a breakfast workshop titled “Breaking Down the New Failure to Prevent Fraud Offence,” in its London office.

From 1 September 2025, large companies—regardless of the jurisdiction in which they are based, formed, or incorporated—may be held criminally liable if found to have directly or indirectly benefitted from a fraud with a UK nexus that was committed by their employees, agents, subsidiaries, or persons deemed to be performing services on their behalf. Convicted companies face a maximum penalty of an unlimited fine. It is a defence, however, for large organisations that find themselves in the crosshairs of the offence to demonstrate that they had a reasonable fraud prevention procedure in place.

The panel—consisting of Jenner Partners Robert Dalling and Lucy Blake, and Associate André Nwadikwa, Grant Thornton Partner Tom Townson and Director Emma Young—discussed what the new corporate criminal offence of Failure to Prevent Fraud means for organisations, what regulators are likely to expect and penalize, and the practical steps that in-house teams can take to build “reasonable fraud prevention procedures” in preparation for the offence entering into force on 1 September 2025.

Jenner & Block Hosted Workshop with Grant Thornton UK on “Breaking Down the New Failure to Prevent Fraud Offence”

Jenner & Block and Grant Thornton UK hosted a breakfast workshop titled “Breaking Down the New Failure to Prevent Fraud Offence,” in its London office.

From 1 September 2025, large companies—regardless of the jurisdiction in which they are based, formed, or incorporated—may be held criminally liable if found to have directly or indirectly benefitted from a fraud with a UK nexus that was committed by their employees, agents, subsidiaries, or persons deemed to be performing services on their behalf. Convicted companies face a maximum penalty of an unlimited fine. It is a defence, however, for large organisations that find themselves in the crosshairs of the offence to demonstrate that they had a reasonable fraud prevention procedure in place.

The panel—consisting of Jenner Partners Robert Dalling and Lucy Blake, and Associate André Nwadikwa, Grant Thornton Partner Tom Townson and Director Emma Young—discussed what the new corporate criminal offence of Failure to Prevent Fraud means for organisations, what regulators are likely to expect and penalize, and the practical steps that in-house teams can take to build “reasonable fraud prevention procedures” in preparation for the offence entering into force on 1 September 2025.

News and Insights

Event

Amanda Shafer Berman to Speak on Energy and Administrative Law at WEN-DC Webinar

As the Supreme Court's new Term begins, Jenner & Block Partner Amanda Shafer Berman will join a Women's Energy Network of Washington, DC (WEN-DC) webinar on how the Court's decisions are shaping the energy sector.

October 14, 2026

Publications

Partner Amanda Shafer Berman Quoted in Bloomberg Law on Senate Permitting Overhaul Bill

Partner Amanda Shafer Berman was quoted in an October 5 Bloomberg Law article, "Permitting Deal Gives Projects Defense Against Litigation Delays," on the Senate's new permitting overhaul package and its expected impact on litigation over federal permitting reversals.

October 2026

Event

Partner John Storino to Speak at Sandpiper Partners' “AI and Outside Counsel Guidelines Roundtable”

On October 8, Partner John Storino will serve as a panelist at the “AI and Outside Counsel Guidelines Roundtable,” hosted by Sandpiper Partners in Chicago.

October 8, 2026

Event

Partner Meghan Greenfield to Speak on Supreme Court Climate Case at Edison Electric Institute's Fall Legal Conference

On Wednesday, October 7, Partner Meghan Greenfield will speak on a panel titled "Boulder County v. Suncor Energy: What the Supreme Court's Climate Case Means for the Energy Industry" at the Edison Electric Institute's Fall Legal Conference in Salt Lake City, Utah.

October 7, 2026

Publications

The Form Rules Everything: A Seventh Circuit Ruling on ERISA's Substantial Compliance Doctrine

Partner Joseph Torres and Special Counsel Jennifer Beach authored an article for Employee Relations Law Journal examining the Seventh Circuit's decision in Packaging Corp. of America Thrift Plan for Hourly Employees v. Langdon, a ruling that addresses both the standard of review in ERISA interpleader actions and the continued viability of the substantial compliance doctrine for changing plan beneficiaries.

October 5, 2026