A UK law that reaches German boardrooms: The new „Failure to Prevent Fraud“ offence and why it matters for German companies
The UK’s new corporate offence of „Failure to Prevent Fraud“ has been in force since 1 September 2025. Introduced by the Economic Crime and Corporate Transparency Act 2023, it can have large organisations criminally liable where an associated person commits fraud intended to benefit the company. The offence carries the risk of unlimited fines, and enforcement authorities have made clear that that they are willing to go after companies that do not have appropriate fraud prevention procedures in place. The Crime and Policing Act 2026 has even extended corporate liability for criminal offences to any offence committed by the senior management.
What many German companies may not yet have fully assessed is that the offence can reach beyond the UK. The UK remains one of the most important markets for German exporters outside the EU, yet a physical presence there is not required for the offence to apply. A company trading with the UK, or operating through a UK subsidiary, may fall within scope where there is a UK connection to the conduct. A defence is available where an organisation had reasonable fraud prevention procedures in place at the relevant time.
Wednesday, 25 June 2026, 12:30–13:30 CEST
➡️Register via this link
In our webinar, Maria Cronin, Partner at Peters & Peters Solicitors in London, and Jasin Sahir, CFE Manager at Pohlmann & Company, will work through examples to show how the offence applies in practice, including how liability can attach to a German parent company and which practical steps German companies should consider now.
What to expect in the webinar:
- An introduction to the offence, including how it can apply to German companies, their UK subsidiaries, illustrated through concrete examples
- Why „fraud“ under UK law is considerably broader than the German concept and why that matters
- An overview of the „reasonable procedures“ defence, the practical steps German companies should take to demonstrate an effective fraud prevention framework and how existing compliance management systems might fit into what is regarded reasonable.
This webinar is aimed in particular at compliance officers, legal, finance and procurement leaders, and managing directors of industrial and trading companies with business relations to the UK
(The webinar will be held in English)
Maria Cronin is Partner at Peters & Peters LLP, a UK based law firm specialising in fraud and commercial disputes and business crime and investigations. She has extensive experience of advising corporate and individual clients on all aspects of business crime, including corruption and money laundering. Her practice focuses on white-collar cases with a truly international dimension.
Jasin Sahir is a Manager at Pohlmann & Company. He advises clients on the prevention, detection and investigation of white-collar crime and has extensive experience in conducting complex internal investigations in both national and international settings. As a former compliance officer and Certified Fraud Examiner (CFE), his practice focuses on fraud investigations, compliance risk management and the development of effective compliance programmes.