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.
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