Previously, prosecutors had to prove wrongdoing by a company’s “directing mind and will” (usually top executives), but the new framework extends liability to a much broader range of senior staff, covering almost all criminal offences—not just economic crimes like fraud or money laundering. As a result, companies can now be held liable where a senior manager commits an offence in the course of their role, even without direct board involvement or clear corporate benefit, greatly widening exposure to fraud, financial crime…