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The provisions relating to declaration of significant beneficial ownership (“SBO”) were introduced in the Companies Act, 2013 (“Act”) with effect from June 2018, to prevent misuse of corporate...
Large organisations worldwide now face unprecedented fraud liability under the UK's Failure to Prevent Fraud Offence, which came into effect on September 1, 2025, creating strict corporate criminal liability even when senior management has no knowledge of the fraud.
CMS INDUSLAW's Amrita Tonk, Arnav Sanyal and Riddhi Jain analyse the extraterritorial implications of the UK's Economic Crime and Corporate Transparency Act’s framework and examine how organisations can navigate compliance challenges through proportionate fraud prevention procedures, risk-based due diligence across complex supply chains and third-party relationships, and robust governance frameworks that extend protection beyond UK borders.
