When Spotlight was established in 2019 there was little realistic probability of the government ever introducing corporate liability reform. However, by the autumn of 2020, we had worked closely with the APPGs on Anti-Corruption and Fair Business Banking to put forward an amendment to the Financial Services Bill to introduce a failure to prevent economic crime offence to address this legislative gap. This included submitting oral and written evidence to the Bill Committee. While the amendment was not successful it laid significant groundwork by showing political support, particularly on the Conservative backbenches, for corporate liability reform.
Following on from this, we worked with Transparency International to lobby the Justice Secretary. This resulted in the Ministry of Justice pushing forward a Law Commission consultation on corporate liability. We engaged closely with the consultation, working with NGOs to submit as many responses as possible, and taking part in Law Commission roundtables to promote the need for reform. In June 2022, the Law Commission finally published an options paper in which it recommended reforms. We worked with partners in Parliament and civil society to issue a robust response to it, and have continued to push the need for ambitious implementation through meetings with civil servants and in parliamentary engagement. There is now a realistic possibility that corporate liability reform will be introduced in the next few years, and even some limited reform accepted as an amendment to the Economic Crime and Corporate Transparency Bill currently before Parliament.