Greenwich Council is set to implement new measures aimed at bolstering its fraud prevention capabilities, following a review by the Audit and Risk Management Panel. The Council is adopting an action plan to implement the requirements of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), which includes addressing the new corporate offence of Failure to Prevent Fraud (FTPF).
This plan focuses on establishing a unified Anti-Fraud Framework based on six key principles, as advised by the Home Office for implementing the ECCTA. These principles are: top-level commitment, risk assessment, proportionate prevention procedures and due diligence, communication, and monitoring and review.
Top-Level Commitment
The 'top-level commitment' principle will be demonstrated and enforced through a formal statement endorsed by Members and senior management, as part of the unified Anti-Fraud Framework. This framework is being developed to address the requirements of the ECCTA.
Proportionate Prevention Procedures and Due Diligence
The unified Anti-Fraud Framework will incorporate existing key controls such as financial regulations, procurement rules, and risk-based checks on contractors and partners as 'proportionate, risk-based prevention procedures and due diligence'. The meeting information does not detail how these measures will be tailored to different risk levels.
Communication and Monitoring
Mechanisms for 'communication' regarding fraud prevention will include the Council's whistleblowing procedure, a dedicated anti-fraud page on the intranet, and targeted fraud awareness sessions. These will be integrated into the unified Anti-Fraud Framework.
The 'monitoring and review' of the Anti-Fraud Framework will be conducted with a reasonable review frequency, such as annually or event-triggered. The framework will include reporting to senior management and Members. The Head of Audit is responsible for the implementation steps of the framework, including communication and integration into guidance and training.
This action plan is being implemented in response to concerns about financial sustainability. Further details on the Council's financial position can be found in the Public reports pack 17th-Mar-2026 18.30 Audit and Risk Management Panel.
