Boards across the UK are re-examining how they manage the risk of economic crime. Recent legislative change has widened the circumstances in which a company can be held responsible for the conduct of those acting on its behalf.
What has changed
The new offence of failing to prevent fraud, and the broader test for attributing criminal liability, mean that senior managers’ conduct can now expose the organisation itself. The practical consequence is that reasonable procedures are no longer optional.
Practical steps for directors
Review your risk assessment, ensure that policies are proportionate and actually followed, and document how decisions are made. A clear audit trail is often the difference between a defensible position and a difficult one.