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The ECCTA is introducing wide-ranging reforms aimed, among other things, at tackling economic crimes (which the Government says make up over 40% of crime in the UK).

The Crime and Policing Act 2026 introduces a universal senior manager attribution test that holds organizations criminally liable for offenses committed by their senior managers. This regime, already in effect since June 2026, poses significant risks for private credit managers whose senior personnel are directly involved in deal approval, portfolio monitoring, and workout activities across UK-connected transactions.