Failure to Prevent Fraud Advisory & Procedures Review
The Failure to Prevent Fraud offence under the Economic Crime and Corporate Transparency Act 2023, in force from 1 September 2025, makes large organisations liable for unlimited fines if employees commit fraud for the organisation's benefit without adequate prevention procedures. Our experts assess existing controls, identify gaps, and advise on reasonable procedures defence.
Our Methodology
| Phase | What We Do | Deliverable |
|---|---|---|
| Scope assessment | Determine whether organisation meets large organisation thresholds and which fraud offences are in scope. | FTPF applicability assessment |
| Controls review | Review existing fraud prevention policies, internal controls, and detection mechanisms. | Controls gap analysis |
| Procedures design | Recommend reasonable fraud prevention procedures aligned with MOJ guidance. | Procedures improvement plan |
| Expert evidence | Provide expert evidence on adequacy of procedures in FTPF proceedings if required. | Expert report on fraud prevention procedures |
Frequently Asked Questions
What is the Failure to Prevent Fraud offence under ECCTA 2023?
In force from 1 September 2025, the FTPF offence makes large organisations (250+ employees, £36m+ turnover, or £18m+ assets) liable for unlimited fines if employees commit specified fraud offences for the organisation's benefit without reasonable fraud prevention procedures in place.
How can an expert witness help with FTPF compliance?
Forensic accountants conduct independent assessments of fraud prevention controls against MOJ guidance, identify gaps before an offence occurs, and provide expert evidence on whether procedures were reasonable if FTPF proceedings are brought.
Need a forensic accountant for employee fraud?
Tell us about your matter and we will connect you with a qualified expert witness. Response within one business day.