What changed
- The 'failure to prevent fraud' corporate offence under the Economic Crime and Corporate Transparency Act 2023 came into force on 1 September 2025.
- Large organisations can be prosecuted if an associated person commits fraud for their benefit, unless they had reasonable fraud-prevention procedures.
- Companies House began phasing in identity verification for directors and persons with significant control from November 2025.
Who's affected
Large UK organisations and overseas groups with UK operations, plus anyone relying on Companies House data for due diligence.
What compliance teams should do now
- Screen associated persons — agents, intermediaries, and key suppliers — not just customers.
- Show your work: "reasonable procedures" is a documentation test.
- Pair Companies House data with sanctions, PEP, and adverse-media checks rather than treating registry data as verified risk.
Get ahead of examiners — run your first correlated sanctions, PEP, and adverse-media search today. Create your free account →
How AMLX helps
AMLX screens counterparties and associated persons against the UK Sanctions List, OFAC, EU, and UN data plus adverse media, with exportable records that support a reasonable-procedures defence.
Built for: Banks & Credit Unions · Law Firms & Advisors · Insurers & Marketplaces · Trust & Corporate Service Providers
Jurisdiction coverage: United Kingdom screening · Jersey screening · Guernsey screening · Isle of Man screening
Related regulatory updates
- FinCEN's 2026 AML/CFT Program Rule Overhaul — FinCEN has proposed a fundamental, risk-based reform of AML/CFT program requirements for every BSA-covered financial institution.
- Investment Adviser AML Rule Delayed to 2028 — FinCEN pushed its investment adviser AML/CFT rule from January 1, 2026 to January 1, 2028 — but the delay is a runway, not an exemption.
- FinCEN Residential Real Estate Rule Vacated — The FinCEN Residential Real Estate Rule took effect March 1, 2026 and was vacated by a federal court in Texas on March 19, 2026. Laundering risk in all-cash deals did not go anywhere.
Frequently asked questions
What is the UK failure to prevent fraud offence compliance change?
The Economic Crime and Corporate Transparency Act made large organisations liable for fraud they fail to prevent, and brought identity verification to Companies House.
Who does this affect?
Large UK organisations and overseas groups with UK operations, plus anyone relying on Companies House data for due diligence.
How can AMLX help us respond?
AMLX screens counterparties and associated persons against the UK Sanctions List, OFAC, EU, and UN data plus adverse media, with exportable records that support a reasonable-procedures defence. You can start on the free tier with no sales call.
Sources
This page summarises public regulatory developments for general information. It is not legal advice; confirm current status with the regulator or your counsel.