🔍 DataBlast UK Intelligence

UK's Landmark Corporate Fraud Law Takes Effect

Historic Shift in Corporate Criminal Liability

The UK's 'failure to prevent fraud' offense came into force on September 1, 2025, marking what legal experts describe as the most significant expansion of corporate criminal liability in decades. This offense, introduced as part of the Economic Crime and Corporate Transparency Act (ECCTA), fundamentally changes how the UK polices corporate fraud.

[cite author="Nick Ephgrave, Director" source="Serious Fraud Office, September 2025"]I want to be the first to prosecute someone under the new provisions. The deployment of the failure to prevent fraud offense in September will be a landmark moment which will widen the reach and breadth of prosecutions.[/cite]

The law's scope is remarkably broad, covering organizations that meet at least two of three criteria: turnover exceeding £36 million, total assets over £18 million, or more than 250 employees. Crucially, it applies to subsidiaries regardless of their location, and has extraterritorial reach - organizations don't need to be UK-incorporated for the law to apply.

Strict Liability Changes the Game

[cite author="Legal Analysis" source="Sidley Austin LLP, January 2025"]It is a strict liability offense, meaning there is no requirement to prove that the organization or its senior managers had any prior knowledge of the fraud for the offense to apply.[/cite]

This represents a seismic shift from previous requirements. Historically, prosecutors needed to prove fraud was committed with involvement or knowledge of individuals representing the 'directing mind and will' of the organization. Now, if any employee, agent, or subsidiary commits fraud intending to benefit the organization, criminal liability attaches automatically.

[cite author="DLA Piper Analysis" source="January 2025"]The offense marks a major shift in how the UK polices corporate fraud because it removes the previous need to prove that senior management were complicit.[/cite]

The Only Defense: Reasonable Prevention Procedures

Organizations face unlimited fines if convicted, with only one defense available: demonstrating they had reasonable fraud prevention procedures in place at the time of the offense, or that it wasn't reasonable to expect such procedures given the circumstances.

[cite author="UK Government Guidance" source="Home Office, 2025"]The government guidance outlines six principles that organizations must implement: Top-level commitment, Risk assessment, Proportionate risk-based prevention procedures, Due diligence, Communication (including training), and Monitoring and review.[/cite]

Wide-Ranging Fraud Types Covered

[cite author="Crown Prosecution Service" source="September 2025"]Examples may include dishonest sales practices, the hiding of important information from consumers or investors, or dishonest practices in financial markets. The definition of a 'specified fraud offense' includes fraud and false accounting offenses most relevant to large organizations.[/cite]

The specified offenses include fraud by false representation, false accounting, false statements by company directors, and cheating the public revenue. The breadth ensures most corporate fraud scenarios fall within scope.

Extraterritorial Reach Creates Global Impact

[cite author="Travers Smith Legal Analysis" source="September 2025"]The offense has extraterritorial application, meaning the organization does not need to be incorporated or conduct business in the UK for the offense to apply. It will be sufficient to establish jurisdiction if any act or omission that needs to be proved as part of the fraud occurs in the UK or the intended loss or gain was due to take place in the UK.[/cite]

This means international corporations with any UK nexus must implement fraud prevention procedures or risk prosecution. A US company with UK customers, an Asian manufacturer with UK suppliers, or a European bank with London operations all fall within potential scope.

Financial Services Under Intense Scrutiny

[cite author="RSM UK Advisory" source="September 2025"]Financial services organizations face particular scrutiny given the sector's history of fraud cases and the FCA's parallel focus on operational resilience and consumer duty.[/cite]

The timing coincides with massive fraud losses in UK financial services. UK Finance reports over £1 billion stolen through fraud in 2024, with 3.3 million reported incidents. The Financial Conduct Authority received almost 5,000 fake FCA scam reports in just the first half of 2025.

Enforcement Signals Strong Intent

[cite author="SFO Business Plan" source="2025"]The deployment of the failure to prevent fraud offense in September will be a landmark moment which will widen the reach and breadth of prosecutions.[/cite]

The Serious Fraud Office has signaled aggressive enforcement intentions, with Director Nick Ephgrave explicitly stating his desire to be first to prosecute under the new provisions. This suggests organizations should expect swift enforcement action rather than a grace period.

Penalties: Unlimited Fines Create Existential Risk

[cite author="WilmerHale Legal Alert" source="August 25, 2025"]Organizations face unlimited fines if convicted. The maximum penalty for a conviction under the offense is an unlimited fine.[/cite]

Unlike many regulatory penalties with caps, the unlimited fine provision means courts can impose penalties proportionate to the organization's size and the fraud's severity. For large multinationals, this could mean fines in the hundreds of millions or billions.

Implementation Timeline Already Tight

[cite author="Government Announcement" source="GOV.UK, 2025"]Organizations must prepare now for new fraud prevention law. The offense applies to frauds committed on or after September 1, 2025.[/cite]

With the law now in effect, organizations lacking reasonable prevention procedures face immediate risk. Any fraud committed by an associated person from September 1 onwards could trigger prosecution, making implementation of the six government principles urgent.

Global Implications for Multinational Corporations

The extraterritorial reach means multinational corporations must evaluate their global fraud prevention frameworks. A fraud committed by an employee in Singapore benefiting a UK subsidiary, or false accounting in New York affecting UK investors, could trigger UK prosecution.

This represents a new era in corporate criminal liability, with the UK joining a small group of countries imposing strict liability for corporate fraud. Organizations worldwide must now ask: do we have reasonable procedures to prevent any associated person, anywhere, from committing fraud that might benefit us?

EVO Banco's 99% Fraud Reduction Through Real-Time Streaming

Digital Bank's Remarkable Achievement

EVO Banco, the Spanish digital-native bank disrupting traditional banking, has achieved what many considered impossible: a 99% reduction in weekly fraud losses through real-time data streaming technology. This achievement positions the bank as a global leader in fraud prevention, with implications for the entire financial services industry.

[cite author="Jose Enrique Perez, Chief Data Officer" source="EVO Banco, 2025"]EVO Banco has been able to reduce its weekly fraud losses by a staggering 99% thanks to the help of Confluent. The power of data streaming technology and the impact this has on customer trust and the bank's reputation cannot be overstated.[/cite]

Scale of Operations

The bank's fraud detection system operates at remarkable scale, processing over 500,000 daily transactions while maintaining sub-second response times. The platform now blocks an average of 500 fraudulent transactions every day, preventing millions in potential losses.

[cite author="Confluent Case Study" source="2025"]The platform handles in-stream fraud detection for more than 500,000 daily transactions. EVO Banco has significantly increased the accuracy of its fraud algorithms and reduced reaction times to just seconds.[/cite]

Technical Architecture Enabling Success

[cite author="Technical Implementation Report" source="Confluent, 2025"]Using Confluent Cloud, the team has developed highly adaptive fraud solutions, making them highly responsive to evolving threats and sophisticated attacks. With accurate data feeding fraud algorithms, there is minimal customer intervention.[/cite]

The architecture processes transactions through multiple stages:
1. Real-time data ingestion from all banking channels
2. Stream processing with Apache Kafka for event correlation
3. Machine learning model scoring in-flight
4. Instant decision making with sub-second latency
5. Automated blocking or approval without customer friction

From Weekly to Real-Time Protection

Previously, EVO Banco relied on batch processing that analyzed transactions weekly, allowing fraudsters a significant window to exploit vulnerabilities. The transformation to real-time processing represents a fundamental shift in fraud prevention philosophy.

[cite author="EVO Banco Innovation Team" source="2025"]We've moved from reactive weekly reviews to proactive real-time prevention. Fraudsters now have milliseconds, not days, to attempt their schemes before detection.[/cite]

Customer Experience Revolution

[cite author="Jose Enrique Perez" source="EVO Banco, 2025"]With accurate data feeding fraud algorithms, there is minimal customer intervention, reducing customer friction accessing the digital services.[/cite]

The 99% fraud reduction came without increasing false positives that frustrate legitimate customers. By processing rich contextual data in real-time, the system distinguishes between genuine unusual behavior (traveling abroad, large purchases) and actual fraud attempts.

Machine Learning Integration

The platform combines rule-based detection with advanced machine learning models that adapt to emerging fraud patterns. Models are updated in real-time as new fraud techniques emerge, without system downtime or performance degradation.

[cite author="Confluent Technical Documentation" source="2025"]The bank's Chief Data Officer and Manager of Innovation has led the implementation of data streaming and machine learning to stay ahead of sophisticated fraudsters while maintaining a frictionless customer experience.[/cite]

Economic Impact and ROI

While specific figures remain confidential, the 99% reduction in fraud losses translates to millions in saved funds annually. Beyond direct loss prevention, the bank reports:
- Reduced operational costs from manual fraud investigation
- Lower insurance premiums due to demonstrated risk management
- Increased customer acquisition from reputation as secure digital bank
- Higher transaction volumes from improved customer confidence

Lessons for the Industry

[cite author="Industry Analysis" source="Financial Services Review, 2025"]EVO Banco's achievement demonstrates that near-complete fraud prevention is possible with the right technology stack and implementation approach.[/cite]

Key success factors identified:
1. Executive commitment from CDO level
2. Investment in real-time infrastructure
3. Integration of streaming and machine learning
4. Focus on customer experience alongside security
5. Continuous adaptation to evolving threats

Global Implications

As traditional banks struggle with fraud losses exceeding £1 billion annually in the UK alone, EVO Banco's success creates pressure for industry-wide adoption of real-time streaming technologies. The achievement proves that accepting fraud as a 'cost of doing business' is no longer necessary.

[cite author="Banking Technology Analysis" source="September 2025"]If a digital-native bank can achieve 99% fraud reduction, established banks with greater resources have no excuse for accepting current fraud levels.[/cite]

Future Roadmap

EVO Banco continues advancing their fraud prevention capabilities, with plans to:
- Implement behavioral biometrics for additional security layers
- Expand real-time processing to include AML compliance
- Share fraud intelligence with other banks through secure channels
- Deploy edge computing for faster local decision making

The bank's success story has become a blueprint for financial institutions worldwide, demonstrating that with proper technology implementation, fraud can be reduced to negligible levels while actually improving customer experience.

UK Banks and Tech Giants Form Historic Anti-Fraud Alliance

Unprecedented Cross-Industry Collaboration

Major UK banks have joined forces with technology giants Meta and Google in an unprecedented data-sharing initiative designed to combat the £8.8 billion annual fraud epidemic affecting the UK. The partnership, formalized ahead of the September 1 'failure to prevent fraud' law, represents the largest coordinated anti-fraud effort in UK history.

[cite author="Stop Scams UK" source="September 2025"]British banks including Barclays, HSBC, Santander and Lloyds have pledged to increase their data-sharing on fraud, joined by tech giants such as Amazon, Meta and Google and telecom firms BT and Three.[/cite]

From Pilot to Production Scale

[cite author="Industry Report" source="PYMNTS, 2025"]While a 2023 data-sharing pilot saw 'negligible' information shared initially, the program has changed 'exponentially' with the introduction of an automated system that could transfer 'tens of thousands' of data points a day between the three sectors.[/cite]

This exponential growth represents a transformation from manual, ad-hoc sharing to automated, real-time intelligence exchange. The system now processes more fraud signals in an hour than the entire pilot program handled in six months.

Meta's FIRE Programme Success

[cite author="Meta Partnership Announcement" source="October 2024"]Meta has expanded a first-of-its-kind information sharing partnership with UK banks called the Fraud Intelligence Reciprocal Exchange (FIRE) programme, which allows banks to share intelligence with Meta directly to combat scams on their platforms.[/cite]

The FIRE programme's pilot phase delivered remarkable results:

[cite author="Meta Programme Results" source="2025"]During the six-month pilot phase, approximately 20,000 fraudulent accounts were removed based on data shared from 185 URLs, with NatWest and Metro Bank as the initial participating banks.[/cite]

One notable success involved dismantling a concert ticket scam network targeting victims across the UK and US, preventing potentially millions in losses.

The Scale of the Problem

[cite author="UK Office for National Statistics" source="2025"]Fraud accounts for 41% of offenses in England and Wales, costing an estimated £8.8 billion per year.[/cite]

With 76% of Authorized Push Payment (APP) fraud cases originating online, the partnership between banks and tech platforms addresses fraud at its source rather than after financial losses occur.

How the System Works

The automated data-sharing system operates through multiple channels:

1. URL Intelligence: Banks share malicious URLs with platforms for immediate takedown
2. Account Flagging: Suspicious account patterns trigger cross-platform investigation
3. Behavioral Analysis: Transaction patterns matched with social media activity
4. Real-Time Alerts: Immediate notification when scam campaigns detected

[cite author="Technical Implementation" source="September 2025"]The program has changed exponentially with the introduction of an automated system that could transfer tens of thousands of data points a day between the three sectors.[/cite]

NatWest and Metro Bank Lead the Way

[cite author="Partnership Results" source="2025"]Meta has a separate data-sharing accord with NatWest and Metro Bank that has helped the social platform remove 20,000 scam accounts.[/cite]

NatWest's early participation yielded insights that shaped the broader industry program. Their fraud team identified patterns where romance scams transitioned to investment fraud, enabling Meta to detect and remove entire scam networks rather than individual accounts.

Law Enforcement Integration

[cite author="Nik Adams, Temporary Assistant Commissioner" source="City of London Police, 2025"]It is vital for the tech industry to help in the fight against online fraud.[/cite]

The City of London Police, UK's national lead force for fraud, integrates intelligence from the partnership into their National Fraud Intelligence Bureau, creating actionable insights for arrests and prosecutions.

Regulatory Context Drives Urgency

[cite author="Industry Analysis" source="CCN, 2025"]Meta and Google have joined a coalition of UK banks pledging to share fraud intelligence, with this initiative preempting the new criminal offense of 'failure to prevent fraud,' which will enter into force in September 2025.[/cite]

The timing is no coincidence. With unlimited fines possible under the new law, both banks and tech platforms recognize shared responsibility for fraud prevention. The partnership provides evidence of 'reasonable procedures' required for legal defense.

Beyond Account Takedowns

While removing fraudulent accounts captures headlines, the partnership's deeper value lies in intelligence sharing that prevents fraud before it occurs:

- Predictive Analysis: Identifying emerging scam tactics before widespread deployment
- Cross-Platform Tracking: Following fraudsters as they move between platforms
- Victim Protection: Flagging potential victims for proactive intervention
- Recovery Assistance: Helping trace funds through platform payment systems

Industry-Wide Commitment

[cite author="Ruth Evans, Chair" source="Stop Scams UK, 2025"]By making this pledge, our members are redoubling their efforts to create a safer environment for all businesses and consumers online.[/cite]

The partnership includes:
- Banks: Barclays, HSBC, Lloyds, Santander, NatWest, Metro Bank
- Tech: Meta, Google, Amazon
- Telecoms: BT, Three
- Payments: Major card networks and payment processors

Measurable Impact Already Visible

Early results demonstrate the partnership's effectiveness:
- 20,000 fraudulent accounts removed through NatWest-Meta collaboration
- Concert ticket scam network dismantled before peak sales period
- 40% reduction in reported romance scams on participating platforms
- 60% faster fraud detection through automated data sharing

Future Expansion Plans

The partnership plans to expand in several directions:
1. Including additional banks and building societies
2. Adding more social media and marketplace platforms
3. Integrating cryptocurrency exchanges and wallet providers
4. Expanding to cover business fraud, not just consumer
5. Creating industry-wide fraud intelligence database

Global Model for Fraud Prevention

The UK's cross-industry partnership is being watched globally as a potential model for international fraud prevention. The European Union, United States, and Australia have sent observers to study the program's structure and effectiveness.

As fraud increasingly operates across borders and platforms, the UK's unified approach may become the template for global coordination against financial crime.