From today, Part 3 of the Criminal Finances Act 2017 creates new corporate offences of failing to prevent the facilitation of UK or foreign tax evasion by an associated person, such as an employee, agent or contractor.
As with the Bribery Act, the only defence is to have reasonable prevention procedures in place, and HMRC has published guidance on what these look like.
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- Prevention procedures rely on accurate, protected records.
- Supplier and partner due diligence must be documented and retained.
- Staff awareness and confidential whistleblowing channels are key controls.
Organisations with an ISO/IEC 27001 management system already have much of the governance, risk assessment and record-keeping discipline needed to support these procedures.
Source: Criminal Finances Act 2017, Part 3 (legislation.gov.uk)
This update is general information, not legal advice. If you would like help assessing the impact on your information security or privacy programme, contact us.
