UK corporate criminal liability under ECCTA 2023: organisation-wide risk assessment and governance template

Published by a LexisNexis Practice Compliance expert

Precedents

1 Introduction

1.1 We have carried out an organisation-wide review of exposure to corporate criminal liability risks. This was undertaken by engaging key stakeholders, including the organisation’s senior figures. Many of the risks mirror those already highlighted through our crime-prevention compliance frameworks, including risk assessment procedures under the Bribery Act 2010, facilitation of tax evasion, failure to prevent fraud, anti-money laundering (AML), counter-terrorist financing (CTF), counter-proliferation financing, etc. We also evaluated broader corporate criminal liability risks as part of this exercise.

1.2 This document sets out the risks assessed, the conclusions reached, and the actions we deem necessary arising from the review.

1.3 The review considered:

1.3.1 who qualifies as a ‘senior manager’ and the extent of their authority;
1.3.2 our governance and oversight arrangements;
1.3.3 the offences captured by the corporate criminal liability provisions within the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023);
1.3.4 our international operations;
1.3.5 our internal channels for raising concerns...

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Web page updated on 22/05/2026

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