ECCTA failure to prevent fraud, by role
The failure-to-prevent-fraud offence touches the whole governance, risk, and compliance committee. These role guides show what each role is accountable for and the evidence they most need — prompts for human judgement, not legal conclusions.
Choose your role
- General CounselTurn scope uncertainty and evidence operations into a reviewable workpaper that keeps adviser judgement separate.
- Heads of ComplianceRun the day-to-day programme — attestations, evidence review, and gap-chasing — as an organised, dated record.
- Company SecretaryHow company secretaries evidence board commitment and governance for the ECCTA failure-to-prevent-fraud offence — a reviewable defence file.
- Chief Risk OfficerHow CROs own the fraud risk assessment and monitoring for the ECCTA offence and keep the evidence reviewable in a defence file.
- Head of Internal AuditHow internal audit provides independent assurance over ECCTA fraud-prevention procedures using a reviewable evidence trail.
- Money Laundering Reporting OfficerHow MLROs extend financial-crime controls to the distinct ECCTA failure-to-prevent-fraud question and keep the evidence reviewable.
- Chief Financial OfficerHow CFOs evidence the finance and procurement controls that matter for the ECCTA failure-to-prevent-fraud offence.
- Chief Operating OfficerHow COOs evidence that fraud-prevention procedures operate across operations and the associated-person base for the ECCTA offence.
- Audit Committee ChairHow audit committee chairs and NEDs evidence oversight and challenge of ECCTA fraud-prevention procedures.
- Compliance OfficerHow compliance officers run day-to-day ECCTA fraud-prevention evidence — attestations, reviews, and a reviewable defence file.
DefenceFile organises evidence for legal and compliance review. It does not provide legal advice, create privilege, certify scope, certify reasonable procedures, or guarantee that a statutory defence will succeed.