Overview

Since 1 September 2025, large UK organisations can be criminally liable if a person associated with them commits fraud intending to benefit the organisation, a genuinely new kind of corporate liability that does not need board-level knowledge. This course explains what the offence actually covers, whether your organisation is likely to be in scope, and what the Home Office's guidance expects a reasonable prevention programme to look like.

Target Audience

All staff and managers in organisations affected by this law. No legal or technical background required.

Learning Objectives

Upon completion, learners will gain a full and clear understanding of:

• What the "failure to prevent fraud" offence criminalises, and why it is a genuinely new kind of corporate liability
• The s.201 thresholds that decide whether an organisation counts as "large" for this offence, and how to check
• The two-limbed statutory defence, and who can count as an "associated person" whose conduct can trigger the offence
• The Home Office's six principles of reasonable prevention procedures, from top level commitment to monitoring and review
• Where training genuinely sits within Principle 5, and why training alone is never the whole answer
• What a practical, proportionate risk assessment, whistleblowing route and training programme might involve

Course Contents

Unit 1: The Offence Itself

What "failure to prevent fraud" actually criminalises, why it is a new kind of corporate liability that needs no board-level knowledge, when it came into force (1 September 2025, SI 2025/349), and the s.201 "large organisation" thresholds in full, with a worked self-assessment for whether an organisation is likely to be in scope.

Unit 2: The Two-Limbed Defence and Who Counts as "Associated"

The statutory defence properly explained as two separate limbs, not a single test, what "associated person" means and why the definition is deliberately wide, and an illustrative overview of the underlying fraud offences that can trigger the offence.

Unit 3: The Home Office Six Principles in Depth

Each of the six principles of reasonable prevention procedures in turn, top level commitment, risk assessment, proportionate procedures, due diligence, communication and training, and monitoring and review, with a close look at what Principle 5 specifically expects of training.

Unit 4: Building Your Organisation's Response

Practical thinking on risk assessment methodology, whistleblowing routes, designing proportionate training tied to Principle 5's requirements, and monitoring and review, closing with a correctly-framed action checklist.