The UK holds companies directly liable for failing to prevent bribery and, since 1 September 2025, for failing to prevent fraud by people acting for them. From 29 June 2026 a company also commits an offence whenever a senior manager commits one within their authority. Both failure to prevent offences reach non-UK companies with UK business, and the only defence is having proportionate prevention procedures in place. Financial sanctions, anti-money laundering registration, modern slavery reporting and employers' liability insurance are separate obligations that apply from day one of trading.
Failure to prevent bribery and fraud
Under section 7 of the Bribery Act 2010 a commercial organisation commits an offence if anyone associated with it, such as an employee, agent or subsidiary, bribes someone to win or keep business for it. It applies to UK companies wherever they operate and to foreign companies that carry on part of their business in the UK. The only defence is proving adequate procedures to prevent bribery.
The failure to prevent fraud offence has applied since 1 September 2025 to large organisations: those meeting two of turnover above £36 million, balance sheet above £18 million and more than 250 employees. The organisation is liable if an associated person commits a listed fraud intending to benefit it, unless it proves reasonable fraud prevention procedures. Groups should run a fraud risk assessment covering sales, reporting and customer-facing activity, not only payments.1234
Senior manager liability
From 29 June 2026 the Crime and Policing Act 2026 makes a company or partnership liable for an offence committed by a senior manager acting within the actual or apparent scope of their authority. This replaced a 2023 rule that applied only to economic crimes. A senior manager is someone who plays a significant role in managing or organising the whole or a substantial part of the business, so the group is wider than the board.5
Sanctions and anti-money laundering
UK financial sanctions are implemented and enforced by the Office of Financial Sanctions Implementation in HM Treasury. UK sanctions lists and licences differ from EU and US ones, so screening must use the UK list specifically.
Businesses in sectors covered by the Money Laundering Regulations, such as trust or company service providers, accountancy service providers, high value dealers and estate agents, need an anti-money laundering supervisor. Those not supervised by the FCA or a professional body must register with HMRC, and trading without registration is an offence.67
Reporting, governance and insurance
Businesses with UK turnover of £36 million or more that supply goods or services must publish an annual modern slavery statement. Listed companies in the commercial companies category follow the UK Corporate Governance Code 2024 on a comply-or-explain basis, with the board declaration on material internal controls applying from financial years beginning on or after 1 January 2026.
Most employers must hold employers' liability insurance of at least £5 million from the first employee, with fines of £2,500 for each day without proper cover.8910
| Obligation | Who it applies to | Defence or threshold |
|---|---|---|
| Failure to prevent bribery | Organisations carrying on business in the UK | Adequate procedures |
| Failure to prevent fraud (from 1 September 2025) | Large organisations: two of turnover above £36m, balance sheet above £18m, more than 250 employees | Reasonable procedures |
| Senior manager attribution (from 29 June 2026) | Bodies corporate and partnerships | Senior manager acting within authority |
| Modern slavery statement | Organisations with turnover of £36m or more doing business in the UK | Annual statement |
| Employers' liability insurance | Most employers | Minimum £5 million cover |
Documents usually needed
- Anti-bribery policy and bribery risk assessment
- Fraud risk assessment and fraud prevention procedures
- Sanctions screening procedure using the UK list
- Anti-money laundering supervisor registration where in scope
- Annual modern slavery statement where the threshold is met
- Employers' liability insurance certificate
Common mistakes
- Assuming the Bribery Act only applies to UK companies; foreign companies with UK business are covered.
- Treating fraud prevention as a payments control issue and missing false reporting or mis-selling by sales teams or agents.
- Screening only against US or EU sanctions lists.
- Starting a trust or company service business before HMRC confirms registration.
- Counting only UK turnover for the modern slavery threshold when subsidiaries' turnover is included.
When the business crosses borders
- Failure to prevent fraud applies to bodies wherever incorporated, so overseas parents meeting the size test can be prosecuted in the UK.
- UK, EU and US sanctions regimes diverge; a transaction permitted in one may need a licence in another.
- Acts of agents and intermediaries abroad can trigger the bribery offence for the organisation that benefits.
Questions businesses ask
Does the failure to prevent fraud offence apply to our non-UK group?
It applies to large bodies corporate and partnerships wherever incorporated, if an associated person commits a listed fraud intended to benefit them.23
What counts as a defence?
For bribery, adequate prevention procedures; for fraud, reasonable prevention procedures, or showing it was not reasonable to expect any.14
Which sanctions authority do we deal with?
The Office of Financial Sanctions Implementation in HM Treasury handles financial sanctions; trade sanctions are handled separately.6
What this guide does not yet confirm
These points need checking with a qualified local professional in the United Kingdom before you rely on them.
- Government guidance on the failure to prevent fraud offence could not yet be checked, so its principles for reasonable procedures and its statement on UK nexus were not confirmed.
- Whistleblowing protection under the Public Interest Disclosure Act 1998, the trade sanctions authority and the list of designated sanctions were not confirmed.
- Announced reforms to anti-money laundering supervision of professional bodies were not checked.
- Whether senior manager attribution applies to conduct before 29 June 2026 was not confirmed.
- Northern Ireland differences for employers' liability insurance were not checked.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
A commercial organisation commits an offence if a person associated with it bribes another person to obtain or retain business or a business advantage for it, unless it proves it had adequate procedures designed to prevent such conduct. Applies to UK-incorporated bodies and partnerships wherever they do business, and to any other body or partnership that carries on a business, or part of a business, in the UK.
The offence of failure to prevent fraud came into force on 1 September 2025: a large organisation is liable where an employee, agent, subsidiary or other person performing services for it commits a listed fraud offence intending to benefit it. Applies to bodies corporate and partnerships wherever incorporated. Not liable where the organisation was the intended victim. Fine, unlimited on indictment.
An organisation is a large organisation for the failure to prevent fraud offence if, in the financial year before the fraud, it met two or more of: turnover above £36 million, balance sheet total above £18 million, and more than 250 employees. Separate rules in sections 201 and 202 apply to parent undertakings and groups.
It is a defence to the failure to prevent fraud offence for the organisation to prove that it had reasonable fraud prevention procedures in place, or that it was not reasonable to expect it to have any.
From 29 June 2026, a company or partnership also commits an offence where a senior manager commits it while acting within the actual or apparent scope of their authority, replacing the narrower 2023 rule that covered economic crimes only. Covers bodies incorporated outside the UK. Excludes cases where all the conduct occurs outside the UK and the organisation would not have committed the offence had the conduct been its own.
Section 196 of the Economic Crime and Corporate Transparency Act 2023 is recorded on legislation.gov.uk as omitted from 29 June 2026. Whether section 250 applies to conduct before that date was not confirmed.
The Office of Financial Sanctions Implementation, part of HM Treasury, implements and enforces UK financial sanctions, including the Russian oil price cap. Trade sanctions are handled separately.
Businesses in sectors covered by the Money Laundering Regulations that are not supervised by the FCA or a professional body, such as trust or company service providers, high value dealers and estate agents, must register with HMRC and must not trade without registering. Money service businesses and trust or company service providers must wait for confirmation of registration; other businesses can trade while the application is processed.
A commercial organisation that supplies goods or services, carries on all or part of its business in the UK and has annual turnover of £36 million or more must publish an annual modern slavery statement. Turnover includes subsidiaries and excludes VAT and trade discounts. Adding the statement to the government registry is encouraged but not required.
Most employers must hold employers' liability insurance from an authorised insurer covering at least £5 million, and can be fined £2,500 for every day they are not properly insured. The GOV.UK page covers England, Scotland and Wales; some employers are exempt. Northern Ireland rules were not checked.
The UK Corporate Governance Code 2024 applies on a comply-or-explain basis to companies in the commercial companies or closed-ended investment funds listing categories for financial years beginning on or after 1 January 2025, with the board declaration on material internal controls (Provision 29) applying from financial years beginning on or after 1 January 2026. Applies to companies in those listing categories wherever incorporated.
Questions on this topic
10 statements on bribery, fraud, sanctions and compliance in the United Kingdom
