Companies that do business in the United Kingdom will soon find themselves subject to a new regime where more people in the organization can be subject to criminal prosecution—and not just for a handful of serious economic crimes.
The Crime and Policing Act, which takes effect at the end of June, deliberately widens the number of people who could be considered “senior managers” depending on their actual and apparent authority. As such, alongside executives, key personnel such as heads of departments, regional managers, and people in positions of influence—including compliance officers—can be considered “senior managers” if warranted, increasing the potential risk for criminal prosecutions for corporates.

