From Compliance to Culture: The UK’s New Failure to Prevent Fraud Regime
CerebraThe UK’s Failure to Prevent Fraud regime moves fraud prevention beyond compliance, placing culture, governance and board accountability at the centre of corporate strategy, with significant implications for Turkish companies connected to the UK market.
The webinar titled “From Compliance to Culture: The UK’s New Failure to Prevent Fraud Regime”, organised by Ethics & Reputation Society (TEİD) and the British Chamber of Commerce in Turkey, where Cerebra is a corporate member, was moderated by Fikret Sebilcioğlu, Founder and CEO of Cerebra and Board Member of TEİD.
Fikret Sebilcioğlu emphasised that the “Failure to Prevent Fraud” regime should not be viewed merely as a technical compliance obligation, noting that it materially reshapes the responsibility framework for boards of directors and senior management. In Sebilcioğlu’s view, this new approach makes fraud prevention a permanent item on companies’ strategic governance agenda. Accordingly, boards should periodically seek clear answers to the following critical questions: “What are the company’s fraud risks? Are the existing internal controls sufficient to mitigate these risks? How should the effectiveness of these controls be monitored and independently validated on a regular basis?”
Sebilcioğlu also noted that boards should ensure a consistent and reliable flow of information through effective governance and oversight mechanisms—without resorting to micro-managing day-to-day operations. In this context, he particularly underlined the importance of boards satisfying themselves that actions agreed in relation to critical risk areas are genuinely implemented and that outcomes are followed up in a systematic manner.
The year 2025 marks a significant turning point in the United Kingdom with the introduction of the new Failure to Prevent Fraud regime in the area of fraud and corporate criminal liability. This new framework goes beyond traditional compliance approaches, placing a clear emphasis on corporate culture, governance structures, and proactive fraud prevention. For companies operating in, or connected to, the UK market – including those based in Türkiye – this development represents not only a legal change, but also a strategic governance challenge that requires immediate attention.
