The compliance officer in the firing line: how COLPs and COFAs in conveyancing firms can manage their personal exposure ahead of the Crime and Policing Act 2026
The corporate veil does not protect a compliance officer. It never did.
From 29 June 2026, section 254 of the Crime and Policing Act 2026 will attribute almost any criminal offence committed by a senior manager to the firm itself. No reasonable procedures defence.
For most COLPs and COFAs in conveyancing, the unwelcome reality is that they are the senior manager.
Limited company, LLP or partnership, the form of the firm makes no difference. The substance of the systems, the authority structures and the contemporaneous record makes all the difference.
We have set out a practical playbook for COLPs and COFAs in conveyancing firms looking to harden their personal position ahead of the deadline. Ten things to do, now.
Link in the comments below.
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