Mark Beardsworth, partner at Signature Litigation, commented:
“There are a lot of mergers and acquisitions [in the financial advice world] which means necessarily more entities fall under the minimum company size provisions covered by the ECCTA offence. The parties to these deals will now be cognisant of the need for the new company to have a mature set of policies which incorporate the guidelines.
“All stakeholders including private equity investors will do their due diligence and expect a proportionate and reasonable fraud prevention policy as a matter of course.
“It’s not just whether you’re going to be targeted by the SFO for a breach but what the overall market expectation is of governance which is driving these changes.”