ECCTA failure to prevent fraud: a guide for compliance officers
Compliance officers do the day-to-day work the defence file depends on: collecting attestations, reviewing evidence, and chasing gaps. DefenceFile turns that work into an organised, dated record instead of a spreadsheet and an inbox.
The sample board pack opens in your browser — no email, no form.
What you are accountable for
You operate the programme day to day — attestation collection, evidence review, gap-chasing — and you produce the record everyone else relies on.
The worries
- Attestations and evidence live in spreadsheets, inboxes, and shared drives
- No single trail of what was reviewed, decided, and still outstanding
- Preparing adviser- or board-ready evidence under time pressure
How the defence file helps
- Collect associated-person attestations with zero-login links
- Review evidence with decisions and notes captured in one place
- Track outstanding items and blockers to closure
- Produce adviser-ready exports and a sign-off-gated board pack
Evidence to prioritise
Associated-person attestations with status and dates
Evidence review decisions and notes
An outstanding-items and blocker list
Compliance Officer questions
- What does day-to-day ECCTA evidence work involve?
- Mapping associated persons, collecting attestations, reviewing fraud-prevention evidence, and tracking gaps — all dated and discoverable. DefenceFile is built for exactly this operating rhythm.
- How do we collect attestations without friction?
- Zero-login attestation links let associated persons confirm without an account, and the status is tracked centrally. The platform organises the responses; it does not vouch for their accuracy.
- Does this give us legal cover?
- No. DefenceFile organises evidence for legal and compliance review; it does not provide legal advice, decide your scope, or guarantee that a statutory defence will succeed.
For other roles
- Head of Internal AuditHow internal audit provides independent assurance over ECCTA fraud-prevention procedures using a reviewable evidence trail.
- Chief Risk OfficerHow CROs own the fraud risk assessment and monitoring for the ECCTA offence and keep the evidence reviewable in a defence file.
- Money Laundering Reporting OfficerHow MLROs extend financial-crime controls to the distinct ECCTA failure-to-prevent-fraud question and keep the evidence reviewable.
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.