"Failure to Prevent Fraud: a New Era?” Solicitors Journal

Partner Joanna Ludlam authored an opinion piece in Solicitors Journal examining the transformative impact of the UK’s newly enacted “failure to prevent fraud” offence under section 199 of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), which took effect in September 2025. In her analysis, Joanna highlights how this landmark legislation reshapes compliance obligations, enforcement dynamics, and procurement risk for large organizations operating in or connected to the UK. 

“This offence is arguably the most significant development in corporate criminal law since the Bribery Act 2010, fundamentally altering the expectations placed on organisations to proactively prevent fraud within their global operations,” said Joanna.  

As Chair of the London Public Law and Crisis Management Practice, and Co-Chair of the firm’s Global Hearing Preparation and Global Crisis Management and Strategic Risk practices, Joanna brings a unique skill set and steady guidance to clients facing sensitive, high stakes matters. She advises major corporations, regulators, and public bodies on complex issues spanning administrative and public law, contentious regulatory investigations, and corporate crime—often involving bribery, fraud, tax evasion, and anti-money laundering—underpinned by her experience in reputation and risk management. 

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

"Failure to Prevent Fraud: a New Era?” Solicitors Journal

Partner Joanna Ludlam authored an opinion piece in Solicitors Journal examining the transformative impact of the UK’s newly enacted “failure to prevent fraud” offence under section 199 of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), which took effect in September 2025. In her analysis, Joanna highlights how this landmark legislation reshapes compliance obligations, enforcement dynamics, and procurement risk for large organizations operating in or connected to the UK. 

“This offence is arguably the most significant development in corporate criminal law since the Bribery Act 2010, fundamentally altering the expectations placed on organisations to proactively prevent fraud within their global operations,” said Joanna.  

As Chair of the London Public Law and Crisis Management Practice, and Co-Chair of the firm’s Global Hearing Preparation and Global Crisis Management and Strategic Risk practices, Joanna brings a unique skill set and steady guidance to clients facing sensitive, high stakes matters. She advises major corporations, regulators, and public bodies on complex issues spanning administrative and public law, contentious regulatory investigations, and corporate crime—often involving bribery, fraud, tax evasion, and anti-money laundering—underpinned by her experience in reputation and risk management. 

Read More

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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