The Failure to Prevent Fraud offence applies to large organisations with a UK Nexus and makes them criminally liable for fraud committed by the Organisation's associated person if the organisation did not have reasonable fraud prevention measures in place at the time the fraud occurred. As a large organisation with a UK Nexus, Oriflame is subject to the offence. A draft risk assessment was created by Oriflame as preparation for the Offence. This thesis assesses whether all reasonable scenarios were identified, conducts a gap analysis of the prevention measures, and provides recommendations.

This thesis was conducted using different methodologies. The first phase consisted of a legal and literature review and a document analysis of the company documents. In the second phase, 5 semi-structured interviews were conducted to identify FTPF-related fraud risks from the perspective of IT Business Support, IT Infrastructure, Tax, Finance and Legal. Based on this, fraud scenarios were created. In the third phase, an expert questionnaire was used to conduct a gap analysis of the prevention measures against the regulatory expectations and recommendations were provided to close the gaps.

The assessment results show that Oriflame has identified the most reasonable fraud scenarios. However, some fraud scenarios were missing or insufficiently developed. They were identified and added. Oriflame also has a strong control environment containing a broad range of both preventive and detective measures. The gap analysis of Oriflame's existing fraud prevention measures against the best practices provided in Home Office guidance published by the UK Government revealed that Oriflame has potential for improvement in documentation, reporting, and governance. A prioritised summary of the gaps was created, and, as a final step, practical recommendations were provided to better align with regulatory expectations and increase Oriflame's compliance readiness.