Evidence the “reasonable procedures”
your supplier screening already does.
Section 199 of the Economic Crime and Corporate Transparency Act 2023 makes large UK organisations criminally liable for fraud by associated persons, unless they can prove reasonable prevention procedures were in place. RecoupIQ records the dated, machine-readable evidence your counsel needs to mount that defence.
How the Evidence Pack works
Screen counterparties
Existing RecoupIQ checks (Companies House identity, OFSI sanctions, FCA Warning List, phoenix screen, beneficial-ownership chain, ECCTA director-ID verification).
Log the decision
Each screening, the human decision, the rationale, and a link back to the full forensic report are written to a tamper-resistant audit trail keyed to your tenant.
Export on demand
GET the Evidence Pack for any date window. Summary roll-ups for the board; full event stream for counsel or for an SFO / FCA enquiry.
What the statute actually requires
The Failure to Prevent Fraud offence applies to a “large organisation”, meeting any two of: >£36m turnover, >£18m balance-sheet total, or >250 employees. Liability attaches when an “associated person” (employee, agent, subsidiary, or third party performing services) commits a relevant fraud offence intending to benefit the organisation or its customers.
The defence is set out in s.199(4): the organisation had “such prevention procedures as it was reasonable in all the circumstances” in place. The Home Office’s November 2024 statutory guidance lists six principles, of which principle 4, “Due diligence on associated persons”, is the one most organisations need help evidencing.
Honesty note. RecoupIQ is a record-keeping product, not a legal-opinion product. We never certify that your procedures are “reasonable” under s.199, that determination rests with your own legal counsel. We surface the evidence they use to make it.
Request enterprise access
Available via Azure Marketplace (separate metering dimension) or direct enterprise agreement. We’ll scope a pilot to your supplier portfolio in 48 hours.