ECCTA failure to prevent fraud: a guide for COOs
Procedures only count if they operate, and operations is where they live — across suppliers, agents, and the people performing services for the business. DefenceFile organises the evidence that operational fraud-prevention procedures are real and working.
The sample board pack opens in your browser — no email, no form.
What you are accountable for
You own the operating reality of fraud-prevention procedures — communication, training, due diligence, and the controls applied across the associated-person base.
The worries
- Procedures are documented but evidence of them operating is thin
- Communication and training records are scattered or undated
- Showing controls reached the wider supplier and agent base
How the defence file helps
- Organise communication, training, and attestation evidence in one place
- Map associated persons and the controls applied to each
- Keep due-diligence and onboarding records discoverable
- Surface operational gaps and blockers for decision
Evidence to prioritise
Communication and training records, dated and attributable
Associated-person and supplier control mapping
Onboarding and due-diligence evidence
Chief Operating Officer questions
- How does operations evidence reasonable procedures?
- Through the record that procedures were communicated, trained, applied, and monitored — the operating reality the guidance's principles describe. DefenceFile organises that record; reasonableness remains a legal judgement.
- How do we evidence controls over a large supplier base?
- Maintain an associated-person register with attestations and due-diligence records linked to your procedures. The platform keeps these review-ready without asserting the base is clean.
- Does the platform run operations for us?
- No. DefenceFile organises the evidence of the controls your teams run; it does not perform due diligence or certify suppliers.
For other roles
- Chief Risk OfficerHow CROs own the fraud risk assessment and monitoring for the ECCTA offence and keep the evidence reviewable in a defence file.
- Chief Financial OfficerHow CFOs evidence the finance and procurement controls that matter for the ECCTA failure-to-prevent-fraud offence.
- Company SecretaryHow company secretaries evidence board commitment and governance for the ECCTA failure-to-prevent-fraud offence — a reviewable defence file.
Keep going
- Failure to prevent fraud: the offence explainedThe statutory offence, the size test, and what a defence file is for.
- Reasonable proceduresHow the six principles map to evidence you can organise.
- Straight answersSourced answers on scope, penalties, and the defence.
- Pricing and pilotsHow a structured pilot review of your evidence works.
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.