INTERPOL has warned that financial fraud is now one of the world’s most serious and rapidly evolving transnational crime threats. Its latest Global Financial Fraud Threat Assessment describes a fraud landscape shaped by artificial intelligence, organised crime, scam centres, human trafficking, cybercrime and specialist money laundering networks. That matters in the UK because failure to prevent liability is becoming a central feature of corporate criminal risk.
The failure to prevent fraud offence, introduced by the Economic Crime and Corporate Transparency Act 2023, has been in force since 1 September 2025. It means large organisations can be held criminally liable where an associated person commits a specified fraud offence intending to benefit the organisation or its clients, unless the organisation can show it had reasonable fraud prevention procedures in place.
But the broader compliance lesson goes beyond one offence. The UK already has failure to prevent offences for bribery and the facilitation of tax evasion. Together, these regimes point towards a much wider expectation: organisations must be able to show that they have identified risk, trained staff, monitored controls, escalated concerns and acted on red flags.
Fraud is becoming more connected
INTERPOL’s report highlights how fraud increasingly sits at the centre of wider criminal activity. Criminal networks are sharing technology, collaborating with specialist money laundering groups and using AI to scale offending. Scam centres, once seen as a regional issue, are now global, with victims from nearly 80 countries trafficked into forced online fraud operations.
That creates a difficult challenge for businesses. A fraud risk may not look like a fraud risk at first. It may appear as a suspicious supplier, a manipulated invoice, an unusual payment route, a high-pressure sales tactic, a fake customer, a compromised employee account, a misleading financial statement or a third party using the organisation’s systems to move money.
In other words, the risk does not sit neatly in one department.
Finance may spot unusual payments. Procurement may see supplier red flags. HR may notice misconduct or pressure on employees. Sales teams may be closest to customer-facing misrepresentation risks. IT and cyber teams may identify business email compromise, account takeover or impersonation attempts. Compliance may hold the policy, but it cannot own the risk alone.
Why this matters for failure to prevent fraud
The UK failure to prevent fraud offence is not aimed only at fraud committed against the organisation. It is concerned with fraud committed by an associated person for the organisation’s benefit, or for the benefit of a client to whom services are provided.
That distinction matters: an organisation might be exposed where employees, agents, subsidiaries or other associated persons engage in dishonest conduct intended to benefit the business. This could include false accounting, misleading sales practices, dishonest statements, abuse of position or other specified fraud offences.
The government’s guidance is clear that organisations should not rely on audit alone as a defence. They need fraud prevention procedures designed around their actual risk profile.
That means asking practical questions:
- Where could our organisation benefit from fraud committed by employees or third parties?
- Which roles, incentives or pressure points create heightened risk?
- Do staff understand the difference between aggressive commercial behaviour and fraud?
- Are fraud risks considered alongside bribery, tax evasion, AML, sanctions, cyber and whistleblowing risks?
- Can we evidence our risk assessment, training, controls, escalation routes and decision-making?
The failure to prevent model is becoming a joined-up compliance challenge
The UK’s failure to prevent regimes are not identical. Failure to prevent bribery, failure to prevent the facilitation of tax evasion and failure to prevent fraud each have their own scope, triggers and defences.
But they share a common direction of travel. Prosecutors and regulators are increasingly interested in whether organisations had working prevention systems in place before misconduct occurred.
That is why treating fraud, bribery and tax evasion as separate training topics or isolated policy areas can create gaps. In practice, the same red flags may cut across multiple risks.
A suspicious third-party payment could raise bribery, fraud, AML and tax evasion concerns. A high-risk intermediary could create corruption and false invoicing risks. A sales team under pressure to meet targets could create risks around misrepresentation, concealment or misleading statements. A supplier with opaque ownership could create financial crime, sanctions and tax risks.
The legal categories may be separate but the real-world warning signs often overlap.
AI is raising the stakes
INTERPOL’s report also points to the growing role of AI in fraud. Deepfakes, voice cloning, impersonation tools and automated fraud campaigns are making it easier for criminals to scale attacks and harder for organisations to spot them quickly.
For compliance teams, this reinforces the need to update fraud risk assessments. Fraud prevention procedures designed around older assumptions may no longer be enough.
Businesses should consider whether staff are trained to recognise AI-enabled impersonation, fake payment instructions, manipulated documents, synthetic identities and social engineering attempts. They should also assess whether cyber, finance, compliance and legal teams have clear routes for sharing concerns.
The more sophisticated fraud becomes, the more important internal communication becomes.
What should organisations do now?
The practical response is not to create a standalone failure to prevent fraud project that sits apart from everything else. Organisations should build a joined-up financial crime framework that connects fraud, bribery, tax evasion, AML, sanctions, cyber risk and whistleblowing.
That means:
- refreshing fraud risk assessments in light of AI-enabled and cross-border threats
- reviewing policies and procedures against the UK failure to prevent fraud guidance
- training staff on real-life fraud risks in their role
- strengthening third-party due diligence and supplier oversight
- checking whether incentives, targets or sales practices could encourage misconduct
- making reporting routes clear and safe
- keeping evidence of decisions, training, investigations and control improvements
Failure to prevent compliance is not about proving that misconduct could never happen. It is about showing that the organisation understood its risks and took reasonable, practical steps to prevent them.
Are your controls seeing the full picture?
INTERPOL’s warning is not simply that fraud is growing. It is that fraud is becoming more connected, more professionalised and more difficult to separate from other financial crime risks.
That is exactly why UK failure to prevent laws matter. They push organisations to move beyond policies on paper and demonstrate active prevention: risk assessment, training, controls, escalation, monitoring and evidence.
