Morris-Cotterill - how to save millions on new compliance costs in the UK
The principles of the proposed offence follow the Bribery Act in that the failure to prevent fraud will be as follows: "Under the new offence, an organisation will be liable where a specified fraud offence is committed by an employee or agent, for the organisation’s benefit, and the organisation did not have reasonable fraud prevention procedures in place. It does not need to be demonstrated that company bosses ordered or knew about the fraud." (source HMG).
It is not consistent with the requirements of the Financial Conduct Authority to protect customers from fraud, which is what was expected.
As it stands, it's little more than a guaranteed honeypot for consultancies and lawyers in relation to "reasonable fraud prevention procedures."
So here's an idea: dust off the bribery policies, make minor adjustments to include fraud, and save millions of pounds.
You heard it here first.
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