The Grey Areas of the ECCTA “Failure to Prevent Fraud” (FTPF) Offence: What It Takes to Make the “Reasonable Procedures” Defence - and What Falls Short

March 2025

Download Recording

Toby Duthie

Founding Partner
FRA (United Kingdom)

Barry Vitou

Partner
HFW (United Kingdom)

The new corporate offence of failure to prevent fraud (FTPF) comes into effect 1 September 2025. Organisations are accordingly upgrading risk management systems to develop ‘reasonable’ prevention policies and procedures.

This complimentary webinar will cover the most significant pitfalls to avoid, the lesser-known aspects of the new offence, as well as key questions to address now before it’s too late.

Topics covered will include:

  • Real-world takeaways from the ECCTA guidance, including key timelines and enforcement expectations
  • Core elements of fraud prevention procedures: What constitutes a “proportionate” risk-based prevention procedure
  • Key pitfalls to avoid when developing and implementing “reasonable procedures”
  • Grey areas to navigate toward mitigating exposure and prosecution risks

Complete the form below to download the recording of the webinar.

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