London insurance partner Steven Francis and associate Eli Levy co-authored an article for FT Adviser examining the forthcoming implementation of Section 250 of the Crime and Policing Act 2026, which significantly expands corporate criminal liability in the United Kingdom by extending attribution to senior managers across a broader range of offences.
Francis and Levy outline the limitations of the existing “directing mind and will” doctrine and explain how the new provisions build on earlier reforms to make prosecutions of large organizations more viable. They further explore the implications for companies, noting that despite the removal of a formal “reasonable procedures” defense under the new regime, strong governance, internal controls and compliance frameworks remain critical to mitigating risk and informing how enforcement authorities evaluate potential cases.
