AFB Practice Workshop: Failure to Prevent Fraud – Testing Internal Controls

One year after the introduction of the UK’s Failure to Prevent Fraud (FTPF) offence, firms are moving beyond implementation and are testing whether their control frameworks are effective in practice.

AFB, in partnership with HKA, invites members to an interactive workshop exploring how the control frameworks are operating one year on, with a particular focus on the challenges and priorities relevant to international firms.

Through facilitated discussion and practical, real case-based examples, the session will examine different approaches firms have taken on design, implementation and the remediation of post implementation gaps. It will also consider what has worked (and what has not) when frameworks have been tested in real scenarios, what good looks like, and what firms might do differently with the benefit of hindsight.

Why attend?

• Understand how control frameworks are working in practice – gain insights into the real-world challenges firms have faced since implementation and how expectations are evolving
• Benchmark your framework against peers – compare approaches to risk assessment, controls, governance, training, monitoring, and documentation
• Learn from real case examples – explore practical scenarios that illustrate where frameworks have succeeded and where weaknesses have been exposed
• Understand common post-implementation findings and how firms have strengthened their controls and governance arrangements
• Hear what “good” looks like – gain practical guidance on effective fraud prevention frameworks and lessons learned from early adopters
• Reduce regulatory, legal, and reputational risk – understand how to evidence “reasonable procedures” and strengthen your institution’s defence against potential enforcement action
• Address specific challenges for non-UK headquartered – discuss issues such as group-wide governance, cross-border control frameworks, parent-subsidiary relationships, and aligning UK requirements with global compliance programmes
• Hear what firms would do differently if implementing their programmes today, helping attendees to avoid common pitfalls

Who should attend?

FTPF is a cross-functional risk that extends beyond traditional compliance teams, so a range of functions would benefit from participating.  This session would be relevant for members working in Compliance, Financial Crime, Legal, Risk, Internal Audit, HR, Operations and Business functions. 

Speakers

Katherine Odendaal is a Managing Director in HKA’s Investigations and Compliance practice with nearly two decades of experience helping multinational organisations navigate complex fraud, misconduct, financial reporting, and regulatory challenges. She has led numerous investigations involving allegations of fraud, bribery, corruption, and other forms of corporate misconduct across a broad range of sectors and jurisdictions. Katherine works closely with clients to establish the facts, assess regulatory and enforcement risks, and identify the control failures, governance weaknesses, and cultural factors that enable wrongdoing to occur. She brings significant expertise in fraud risk assessment, compliance programme enhancement, and the design of robust anti-fraud frameworks, helping organisations strengthen governance, mitigate fraud risks, and evidence effective prevention procedures.

Noémi Klein is a Director in HKA’s Investigations & Compliance team with more than a decade of experience advising global financial institutions on financial crime risk management, governance and regulatory compliance.

Over the past two years, Noémi has supported firms in preparing for and implementing the UK’s Failure to Prevent Fraud (FTPF) regime, helping organisations assess fraud risks, evaluate the effectiveness of existing prevention frameworks, identify control gaps and design practical, proportionate measures to meet the “reasonable procedures” defence. Her experience includes reviewing fraud governance, risk assessments, training, controls, monitoring and assurance frameworks, as well as supporting remediation and enhancement programmes following implementation.

Drawing on extensive experience across Skilled Person Reviews, business-wide risk assessments and major transformation programmes, Noémi brings practical insight into what effective fraud prevention looks like in practice, particularly for complex international organisations operating across multiple jurisdictions.

Please note you will receive confirmation of your booking via email within 24 hours. Should you not receive confirmation, please contact AFB to double-check if your booking was successful.

Logistics

Fee: £275 + VAT

Location: In-person at HKA Global, 100 Victoria Embankment, London EC4Y 0DH

Date: Tuesday 29 September 2026

Time: 09:00 – 11:00 (Registration, networking and breakfast 08:30 – 09:00)

Places: Maximum of 20 people

If you would like to submit a question or have any specific areas that you would like the session to address, please send them to the AFB at secretariat@foreignbanks.org.uk.

You will receive final event details one week before the event.

You will only be deemed to have attended (for CPD points) if you have made yourself known at registration and attend 50% or more of the session.

Please note that the cost charged for this event is payable to Association of Foreign Banks. HKA is not charging AFB or members for hosting this event.  The delegate fees received for this workshop are invested in the ongoing running and administration of AFB.