With the Criminal Finances Act 2017 due to come into force at the end of this month, is your business ready to comply?
The Act creates a new criminal offence for companies or partnerships ‘failing to prevent the facilitation of tax evasion’, by either a member of staff or an external agent. The recent dawn raids of two English football clubs act as a clear warning from HMRC that it will take active steps to investigate and enforce this.
Here are DLA Piper’s top 10 tips for companies when officers come knocking at the door. These tips should form the starting point of your dawn raid policy.
Preparation is key to being prepared:
- Risk assessment
- Proportionality of risk-based prevention procedures
- Top level commitment
- Due diligence
- Communication (including training)
- Monitoring and review
For these offences, the only defence is to have an adequate compliance programme in place, which has reasonable prevention procedures in place. For compliance programmes to be truly effective, a communication campaign is pivotal.
Challenge the process
For help creating your compliance programme, consisting of a policy, training material, a whistleblowing procedure and other supporting communications, get in touch with EXIMIA. We have expertise in compliance and creative, making it easy for you to achieve best practice and beyond.