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The ‘Failure to Prevent Fraud’ Offence: A Phased Approach to Implementing Effective Fraud Prevention Procedures

The Economic Crime and Corporate Transparency Act 2023 (the “ECCTA”) introduced a corporate ‘failure to prevent fraud’ offence providing that ‘large’ organisations may be held criminally liable if an ‘associate’ (such as an...more

Upcoming Reforms to Corporate Criminal Liability in the UK

Traditionally in UK law, in order to hold a company criminally liable, enforcement authorities must prove wrongdoing by a senior person representing the company’s “controlling mind and will.” Through this “identification...more

Continued Anti-Corruption Enforcement by Multilateral Development Banks Highlights Risks for Non-Compliant Companies

Recent debarments of contractors by the World Bank underscore the need for entities working under multilateral development bank (“MDB”) contracts to implement effective anti-corruption project finance mitigation strategies...more

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