The failure to prevent fraud in the UK: what impact will this have on French companies?

Section 199 of the Economic Crime and Corporate Transparency Act 2023 (“ECCTA”), introduced as of 1 September 2025, a new failure to prevent fraud offence applicable to “large companies”. This offence carries unlimited fines unless the organisation can demonstrate that it had “reasonable procedures” in place to prevent fraud. Its extraterritorial scope is likely to affect French companies with links to the United Kingdom, whether directly or indirectly.