The Economic Crime and Corporate Transparency Act (ECCTA) forces UK companies to examine their risk, compliance and governance structures. It’s not just about responding to fraud anymore; it’s proving that you’ve done the work to prevent it. That means risk assessments, cross-department collaboration and a shift in mindset from reactive to proactive.
Know your “associated persons”
One of the most essential concepts under ECCTA is the idea of “associated persons.” These individuals or entities serve your company, contractors, agents, subsidiaries or consultants. The definition is broad and misunderstanding it could leave your business exposed. Legal teams must be involved early to help define who these people are in your context, and companies should maintain a precise and up-to-date associated persons register. Who are they? What do they do for you? Are they operating in high-risk areas? If you don’t know the answers, you’re not ready.
Fraud prevention: From victim to accountability.
Most organizations are conditioned to see fraud only in terms of victimhood. But under ECCTA, the responsibility shifts. Companies must assess where their operations and people could create or enable economic crime. This isn’t just a compliance issue; it’s a cultural one. Building a strong fraud prevention strategy requires involving all areas of the business: finance, HR, commercial, procurement, risk and legal.
Start by conducting a gap analysis; look at what systems and controls you already have, where you fall short and what needs adding. Fraud touches every department of your business, and so must your response.
Risk assessments must be actionable
Risk assessments can’t be a one-and-done exercise. Many companies complete them and then file them away. That’s a mistake. The real work comes after: What controls are in place? Are they sufficient? Are they working in practice? Who’s testing them? Plugging gaps is one part of the job; demonstrating that you’ve done it is another. If regulators call, you must prove you’ve assessed and mitigated risk, not just claim you’ve done so.
Modern slavery, supply chains and due diligence
Modern slavery statements are now under increased scrutiny. It’s not enough to meet the minimum standards. Companies need to examine their practices honestly and holistically. Who are you working with? Who are your customers? In a world of digital business and global suppliers, surface-level checks won’t cut it. Due diligence must go beyond a tick-box exercise. You must understand your counterparties and document how and why you trust them.
Leadership and culture matter
One of the clearest signals of an effective compliance environment is leadership engagement. Are senior executives dedicating time, money and attention to economic crime prevention? Do they follow up on internal controls and risk reports? A strong risk culture starts at the top; without leadership buy-in, even the best policies are doomed to fail.
This is your legal defense
Ultimately, your prevention strategy is your defense. If something goes wrong, regulators and courts will ask: What did you do to stop it? ECCTA is clear: having prevention procedures in place may offer a defense, but only if those procedures are meaningful, documented and enforced. The stakes are high. Make sure your organization is ready.
Unsure where to start? Discover how NAVEX solutions can help your business comply with ECCTA guidelines and other global regulations.
