The U.K.’s upcoming “failure to prevent fraud” offense (FTPF Offense) takes effect on September 1, 2025, and is the subject of guidance that the U.K. Home Office published on November 6, 2024, as part of the implementation of the Economic Crime and Corporate Transparency Act 2023 (ECCTA). The ECCTA lowered the bar for U.K. authorities to prosecute corporations for economic crimes, making large organizations criminally liable for frauds committed for their benefit. But, as detailed in a recent Gibson Dunn webinar, organizations will have a defense against the FTPF Offense if they had reasonable procedures in place to prevent fraud or they can demonstrate that it would not have been reasonable to have had fraud prevention procedures in place. This article summarizes key takeaways from the webinar. See “U.K. Enhances Anti-Fraud Efforts With Economic Crime and Corporate Transparency Act” (Jan. 17, 2024).