Failure to Prevent Fraud - The Operational Playbook

From 1 September 2025, the Failure to Prevent Fraud (FtPF) offence will come into effect – holding organisations criminally liable if an associated person commits fraud for the organisation’s benefit, and reasonable prevention procedures were not in place. 

To help firms respond, we’ve created an operational playbook designed to support practical implementation – not just policy alignment. 

What’s Inside the Playbook 
✅ Key compliance deadlines and what firms should do immediately 
✅ Operational steps across governance, controls, training, due diligence, and monitoring 
✅ Lessons from existing regimes (UK Bribery Act, Failure to Prevent Tax Evasion) 
✅ Guidance on how to review, enhance, and evidence existing frameworks 
✅ A breakdown of what “reasonable fraud prevention procedures” look like in practice 

This isn’t about starting from zero. 
It’s about building on what’s already in place — ensuring your approach is proportionate, effective, and defensible under the new law.