Every year, without fail, the government promises to get tough on financial crime.

This time round, the latest proposal involves extending the “failure to prevent” model to make firms criminally liable for failing to prevent economic crimes beyond bribery and tax evasion unless they have adequate procedures in place.

The model was first introduced by the Bribery Act 2010, with many taking the view that this latest proposal is a welcome necessary and overdue extension as the Act is seen as having been successful at holding companies to account.

In this article for The Times, Neil Swift discusses why the proposal is riddled with difficulty.