Our experts are continuing the discussion about the impact of the Economic Crime and Corporate Transparency Act 2023 (“ECCTA”) and corporate criminal liability with two more sessions.
Session One: Life after the directing mind: new corporate criminal liabilities for senior manager conduct
ECCTA introduced a fundamental shift in corporate criminal liability through the new senior manager test and is already having significant impact on our client’s compliance programmes and investigations. The Act expanded liability beyond the traditional “directing mind and will”, meaning organisations now face increased exposure where senior managers engage in misconduct.
The Crime and Policing Act 2026 builds on ECCTA and, from 29 June 2026, companies and firms will be criminally liable for any offence committed by a senior manager acting within the actual or apparent scope of their authority. Who are an organisation’s senior managers and what can you do to prepare for this far-reaching development?
Our compliance, regulatory, and fraud experts will explore what this change means for businesses, answering some questions we are frequently asked:
- Who qualifies as a “senior manager”?
- How do we know if our governance structures are fit for purpose?
- How do we manage investigations where senior managers are in scope?
