Fraud Costs UK Financial Services Billions Every Year. Most Firms' Policies Don't Cover Half of How It Happens.
The Fraud Act 2006 creates three distinct criminal offences — false representation, failing to disclose, and abuse of position — and your firm can face corporate liability for fraud committed by anyone acting on your behalf. Beyond the criminal exposure, the FCA treats fraud prevention as a core regulatory obligation under SYSC, PRIN, and Consumer Duty. This comprehensive Anti-Fraud Policy gives FCA-regulated firms a full-spectrum framework covering internal fraud, external fraud, financial crime integration, and regulatory governance — built to satisfy both the criminal law standard and FCA supervisory expectations.
Customise with your firm name and FRN. Board-approve it. Evidence your controls.
What's included: Zero-tolerance policy statement with SM&CR accountability framework · Full Fraud Act 2006 legal analysis (Sections 1-4) — false representation, failing to disclose, abuse of position · Dishonesty test per Ivey v Genting Casinos [2017] UKSC 67 · Criminal penalties (10-year imprisonment, unlimited fines) and regulatory consequences (FIT 2.1, Section 56 FSMA) · Corporate liability framework under Fraud Act Section 12 · Financial services sector risk mapping by offence type (consumer credit, insurance, investment, payment services) · Internal fraud risk catalogue (asset misappropriation, payroll fraud, procurement fraud, expense fraud, data theft) · Segregation of duties matrix across cash management, onboarding, payments, and regulatory reporting · Role-based access controls per SYSC 3.2.20R · High-risk role identification (portfolio managers, client money administrators, credit officers, IT administrators) · Red flag indicator library for position abuse detection · External fraud threat taxonomy (identity, application, payment, cyber, investment, insurance, first/third-party) · Product vulnerability assessment framework · Real-time transaction monitoring and behavioural analytics integration · POCA 2002 predicate offence and SAR reporting triggers with timeframes · AML/MLR 2017 integration — CDD, EDD, and transaction monitoring alignment · Sanctions screening integration (SAMLA, OFSI) · Four-tier escalation matrix by fraud value (under £10k through to full Board) · 48-hour investigation initiation requirement · Whistleblowing protection (PIDA 1998, SYSC 18) with multi-channel reporting · FCA notification triggers and one-business-day reporting requirements · Three-lines-of-defence governance model · Board, Risk Committee, and Audit Committee fraud reporting schedule · PRIN obligations mapping (Principles 1, 2, 3, 6, 11) · SYSC 4.1.1R, 6.1.1R, 6.3.1R compliance framework
Built for: Compliance officers, MLROs, risk functions, and boards at FCA-regulated firms who need a Fraud Act-compliant, FCA-ready anti-fraud framework integrated with their existing financial crime programme.
Fraud Costs UK Financial Services Billions Every Year. Most Firms' Policies Don't Cover Half of How It Happens.
The Fraud Act 2006 creates three distinct criminal offences — false representation, failing to disclose, and abuse of position — and your firm can face corporate liability for fraud committed by anyone acting on your behalf. Beyond the criminal exposure, the FCA treats fraud prevention as a core regulatory obligation under SYSC, PRIN, and Consumer Duty. This comprehensive Anti-Fraud Policy gives FCA-regulated firms a full-spectrum framework covering internal fraud, external fraud, financial crime integration, and regulatory governance — built to satisfy both the criminal law standard and FCA supervisory expectations.
Customise with your firm name and FRN. Board-approve it. Evidence your controls.
What's included: Zero-tolerance policy statement with SM&CR accountability framework · Full Fraud Act 2006 legal analysis (Sections 1-4) — false representation, failing to disclose, abuse of position · Dishonesty test per Ivey v Genting Casinos [2017] UKSC 67 · Criminal penalties (10-year imprisonment, unlimited fines) and regulatory consequences (FIT 2.1, Section 56 FSMA) · Corporate liability framework under Fraud Act Section 12 · Financial services sector risk mapping by offence type (consumer credit, insurance, investment, payment services) · Internal fraud risk catalogue (asset misappropriation, payroll fraud, procurement fraud, expense fraud, data theft) · Segregation of duties matrix across cash management, onboarding, payments, and regulatory reporting · Role-based access controls per SYSC 3.2.20R · High-risk role identification (portfolio managers, client money administrators, credit officers, IT administrators) · Red flag indicator library for position abuse detection · External fraud threat taxonomy (identity, application, payment, cyber, investment, insurance, first/third-party) · Product vulnerability assessment framework · Real-time transaction monitoring and behavioural analytics integration · POCA 2002 predicate offence and SAR reporting triggers with timeframes · AML/MLR 2017 integration — CDD, EDD, and transaction monitoring alignment · Sanctions screening integration (SAMLA, OFSI) · Four-tier escalation matrix by fraud value (under £10k through to full Board) · 48-hour investigation initiation requirement · Whistleblowing protection (PIDA 1998, SYSC 18) with multi-channel reporting · FCA notification triggers and one-business-day reporting requirements · Three-lines-of-defence governance model · Board, Risk Committee, and Audit Committee fraud reporting schedule · PRIN obligations mapping (Principles 1, 2, 3, 6, 11) · SYSC 4.1.1R, 6.1.1R, 6.3.1R compliance framework
Built for: Compliance officers, MLROs, risk functions, and boards at FCA-regulated firms who need a Fraud Act-compliant, FCA-ready anti-fraud framework integrated with their existing financial crime programme.
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