Partner Chris Roberts has provided comment in Compliance Week on what companies need to know about the Crime & Policing Act taking effect at the end of June.

Commenting on the implications for companies, Chris said: “With the Crime & Policing Act receiving Royal Assent, companies will no doubt feel that they are being loaded with yet more responsibility, now potentially being liable for any acts that a senior manager may have committed in the course or apparent scope of their authority.

“They will no doubt feel that the risk has been ratcheted up by governments of both colours, with the increase in failure to prevent offences, and now attribution of liability for all criminal offences, not just, as was the case after 2023, specific economic crime offences.

On advising companies on how to respond to the new legislation, Chris commented: “However, any company taking its compliance obligations seriously will have faced all these previous changes head on, and can use that experience to update the policies, procedures and controls to reflect the new legislation. Companies can use this as an opportunity to map the responsibilities of senior individuals, providing them with enhanced training and oversight and leveraging the work done when the “senior manager” test came in for specific economic crime offences.

“It is important to note that this is not a new criminal offence – it is a new method of attributing criminal liability to the company. This means that there is not a statutory defence of, for example, having reasonable procedures in place, as is the case with the new failure to prevent fraud offence. The effectiveness of policies, procedures and controls will be not only critical to prevent an offence happening in the first place but also for mitigation should any offence be proved.

Highlighting the changes for prosecutors, Chris added: “This new method of attributing liability gives prosecutors a potentially more straightforward route to prosecuting corporates for the offences of a senior individual – an issue that has proved very difficult in the past. Whilst there does not yet appear to have been a prosecution using this new method of attribution for economic crime offences, much less a conviction, this now gives prosecutors greater scope to open an investigation into a company as well as the senior individual. For that reason alone, companies should take this new development seriously.”

Chris’ comments were published in Compliance Week, 22 May 2026.