Senior manager (s.196)
A separate ECCTA corporate-liability route for senior-manager conduct under s.196, distinct from the s.199 failure-to-prevent-fraud offence.
Source baseline: 2026-06-15
Plain-language use
Senior-manager liability is a different route from the failure-to-prevent-fraud workflow, so evidence teams should not collapse the two tests into one checklist.
Safe use: Use to flag the distinction between s.196 and s.199; leave liability analysis to legal reviewers.
Official sources
- Economic Crime and Corporate Transparency Act 2023
Royal Assent 2023-10-26; accessed 2026-06-15.
- Joint CPS-SFO Corporate Prosecutions guidance
Updated 2025-11-10; accessed 2026-06-15.