From 1 September 2025, large organisations must be able to demonstrate they have adequate procedures in place to prevent fraud committed by employees and associates.
Under the Economic Crime and Corporate Transparency Act 2023, the new corporate offence of Failure to Prevent Fraud applies to organisations meeting at least two of the following criteria:
- 250 employees or more
- Annual turnover exceeding £36 million
- More than £18 million in total assets
These criteria apply to the whole organisation, including subsidiaries, regardless of where the organisation is headquartered or where its subsidiaries are located.
If fraud is committed by someone associated with your organisation for your benefit, you could face unlimited fines unless you can prove that you had reasonable fraud prevention procedures in place.
This landmark legislation is intended to move businesses away from reacting to fraud after the fact and instead take proactive steps to mitigate risks before they occur. Importantly, the offence applies to fraud committed anywhere in the world if the organisation has strong UK connections.
What You Need to Do Now
With just days to go, organisations should act quickly to:
- Review the Home Office guidance on reasonable fraud prevention procedures
- Conduct a fraud risk assessment across business operations
- Introduce or update internal controls, reporting lines, and whistleblowing channels
- Provide fraud awareness training for staff at all levels
- Document and evidence the steps being taken
Don’t wait until it’s too late. The reputational and financial consequences of inaction could be severe.
How Capcon Argen Can Help
Capcon Argen works with boards, leadership teams, and compliance functions to design and implement robust, defensible fraud prevention frameworks. Our services include:
- High-level fraud risk assessments across complex organisations
- Executive and associate screening to identify potential red flags at senior levels
- Investigations and intelligence gathering where fraud is suspected
- Tailored fraud prevention training for boards and staff
- Compliance audits to ensure procedures meet regulatory expectations
We bring decades of experience in intelligence, investigations, and risk management, ensuring your organisation is prepared, protected, and positioned to meet its obligations under the new law.
Contact Capcon Argen to discuss how we can help you protect your business.
Review the official Home Office guidance here: Home Office Guidance on Failure to Prevent Fraud
