At our last Financial Crime Working Group meeting earlier in the month, we discussed the possibility of developing some kind of framework for the forthcoming ‘failure to prevent fraud’ legislation going live.
Walker Morris have kindly agreed to share their Failure to Prevent Fraud Risk Assessment template, which will hopefully help guide members in the right direction as they develop their policies prior to 1 September.
Please note the floating guidance notes marked [i], which should be visible when you hover over them.
It’s also important to note the following key health warnings:
- this template is intended as a guide only, and should not be construed as legal advice; and
- Any risk assessment will need to be tailored to each member firm and questions should be re-worked to be firm specific.
If you are interested in pursuing this template further, please let me know. Otherwise, I hope you find the information in it useful as you develop your own policies.
In the meantime, a big thanks to Jocelyne Girgis (jocelyne.girgis@walkermorris.co.uk and Andrew Northage (andrew.northage@walkermorris.co.uk at Walker Morris LLP, who can be contacted directly.
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