Many UK businesses still unprepared for new fraud offence Dentons launches toolkit to help

London-The UK's new Failure to Prevent Fraud (FTP) offence comes into force today (1 September), but many businesses remain underprepared to comply with their legal obligations, according to global law firm Dentons.

Discussions with industry and informal research conducted by Dentons from February through to June 2025 showed companies have been slow to take the necessary steps to get ready for FTP compliance.

As of June this year:

• 30% of businesses spoken to had not appointed anyone to oversee FTP compliance;
• Of the 70% that had taken measures, most had assigned FTP responsibilities to already stretched compliance teams in need of support; and
• 78% had not completed - or even begun - a fraud risk assessment, a key component of the 'reasonable procedures' described in government guidance.

Even as of August 2025, businesses across multiple sectors - including high-risk industries like financial services, real estate and construction - reported limited progress, citing competing demands on compliance functions as the main barrier.
In response, Dentons has launched a practical, user-friendly FTP Toolkit to help organisations assess and address gaps in their fraud prevention measures.

FTP was introduced as part of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) and creates a strict liability criminal offence for in-scope companies that fail to prevent fraud by individuals associated with them, where the fraud benefits the organisation or its customers. The only defence is to demonstrate that reasonable and proportionate fraud controls were in place.

The Serious Fraud Office (SFO) has made clear it will prioritise enforcement of the new offence. SFO Director Nick Ephgrave stated:

"I'm very, very keen to prosecute someone for [this] offence. We can't sit with the statute books gathering dust - someone needs to feel the bite."

Helping businesses catch up

Dentons' new FTP Toolkit is designed to simplify the compliance process, enabling businesses to:

• Rapidly evaluate their current level of FTP readiness
• Identify gaps in policies, procedures, and controls
• Take targeted, proportionate actions to meet legal requirements

Sarah Partridge-Smith, counsel and fraud specialist in Dentons' regulatory and investigations team and lead developer of the toolkit, commented:

"The introduction of FTP marks a significant shift in the UK's corporate fraud landscape. It is a strict liability offence, meaning companies will not be able to rely on good intentions or retrospective justifications in place of robust, proportionate and bespoke fraud prevention measures.

"Our data shows that there is still a lack of preparation across industry, which is understandable given today's competing compliance workload. However, with the offence coming into force on 1 September, there is now an urgent need for in-scope firms to ensure that they are sufficiently protected.

"We are particularly mindful about the pressure on overburdened compliance teams. We have designed the FTP Toolkit to try and ease that burden, helping teams act identify gaps and effectively meet their obligations."

Access Dentons' Failure to Prevent Fraud Toolkit.

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