The bar for corporate accountability has risen sharply. Reasonable procedures are now a legal defence, named officers are personally visible, and supervisors expect controls that work in practice rather than on paper. We hold the named role where you need it, and we build the controls behind it, with someone who has carried the responsibility before.
Fractional MLRO and deputy cover, accountable on your register today, supported by the controls behind the role.
Risk assessment, reasonable procedures and documented controls that stand up as a defence under the new offence.
Frameworks, policies and risk assessments built for your business, not lifted from a template.
Screening design, escalation and the judgement calls on exposure that cannot be left to a system alone.
Onboarding and customer due diligence that satisfies the regulator without grinding the business to a halt.
Internal investigations, suspicious activity reporting and the calm handling of a matter that has already gone wrong.
The failure to prevent fraud offence took effect on 1 September 2025, making 2026 its first full year of enforcement. A large organisation can be criminally liable, with an unlimited fine, where an associated person commits fraud intended to benefit it and reasonable prevention procedures were not in place. The only defence is to have built those procedures, and to be able to evidence them. We design, document and stress test exactly that.
Introduced by the Economic Crime and Corporate Transparency Act, it makes large organisations criminally liable where an associated person commits a specified fraud intended to benefit the organisation and reasonable prevention procedures were not in place. It took effect on 1 September 2025.
It applies to large organisations meeting two of three thresholds on turnover, balance sheet and employee numbers, and it can reach conduct connected to the UK even where the organisation sits elsewhere. We assess your position and build the defence.
Yes. We provide named MLRO and deputy cover on a fractional basis, accountable on your register, with the controls and reporting behind the role.