Workshop overview

The introduction of the 'failure to prevent fraud offence' in the Economic Crime and Corporate Transparency Act 2023 (ECCTA) was the next step on the government's road to holding corporate entities more accountable for financial crime and encourage them to take a more proactive approach to fraud prevention, including the implementation of robust prevention procedures to avoid liability. This represents a further layer of financial crime compliance obligations and appropriate compliance gap analysis for the financial services sector. 

With the deadline for having 'reasonable procedures' in place approaching fast, this workshop is designed to prepare firms for the final stages of readiness for the September 2025 deadline. It is focused on a robust risk assessment, tailored procedures implementation, and key risk factors for the future.

Learning outcomes:

  • setting out the mechanics of the offence
  • highlight the specific risk factors for the financial service sector
  • discuss the government guidance – the insights and pitfalls
  • insight into the likely approach to enforcement action
  • a run-down of future-focused top-tips

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Area of expertise:
Nick Price

Nick Price

Partner, Osborne Clarke

Nick has years of experience acting for financial institutions, regulated individuals, and other participants in the financial services sector. He hel...

Nick has years of experience acting for financial institutions, regulated individuals, and other participants in the financial services sector. He helps clients navigate related compliance areas, including AML and financial and trade sanctions.  He has a particular focus in the digital assets space and was a founding member of the crypto-fraud networking group CFAAR.

Nick helps regulated firms with risk of investigation or enforcement action by regulators and disputes in the financial services, crypto assets, and fintech sectors. He regularly advises clients on business-critical investigations, judicial reviews, and high-value disputes in the private equity / M&A space, particularly those arising out of fraud.

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Jeremy Summers

Jeremy Summers

Partner, Osborne Clarke

Jeremy heads the Osborne Clarke business crime offering with over 35 years of expertise gained both in London and Hong Kong, specialising in bribery, ...

Jeremy heads the Osborne Clarke business crime offering with over 35 years of expertise gained both in London and Hong Kong, specialising in bribery, fraud AML and market abuse investigations. 

He has a prominent position in the market and routinely advises clients in the financial services sector on a range of business crime issues from compliance to enforcement. He is frequently asked for expert comment by leading news organisations.

Jeremy additionally sits as leading sports arbitrator chairing disciplinary panels for World Rugby, the National Anti-Doping Panel, the FA and LTA.

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This workshop is ideal for: 

  • Compliance Officers
  • Risk Managers/Analysts
  • Internal Auditors/Audit Managers
  • Operational Risk teams
  • Technology and Cybersecurity leads
  • Fraud Investigator
  • Fraud Prevention Specialists
  • Fraud Risk Manager
  • Fraud Intelligence Officer
  • Financial Crime Compliance teams