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CRIMINAL FINANCES ACT 2017 | BDO UK
DEVELOPING YOUR CCO DEFENCE THE RISK ASSESSMENT
UNDERTAKING A RISK ASSESSMENT
THE TYPICAL PROCESS
BDO’s approach to CCO is focused first on undertaking the Risk Assessment followed by the phased implementation of further defences as needed. Our specialist tax risk team have developed a methodology to provide a level of assurance. The benefits for you of our approach: A CCO report that will be your supporting evidence that you have undertaken a Risk Assessment. This includes detailed and summary Risk Registers that our clients can share with HMRC with confidence Benchmark to our CCO Risk Database built up over our work with over 150 clients Use of established CCO risk templates and presentation decks to share across your business and in workshops Development of a roadmap of prioritised actions to update and introduce prevention procedures Summary of main risk areas and practical next steps 2. 3. 4. 5. 1.
Your first step should be to determine the nature and extent of exposure to the risk of any “associated persons” engaging in activity to criminally facilitate tax evasion. The risk assessment should identify these risks and consider the extent of reasonable prevention procedures to mitigate these risks, with these being proportionate to the size, complexity and risk profile of your business. Our approach to the CCO risk assessment is centred around our facilitated CCO workshop. This includes both an initial training session and an opportunity to work with relevant stakeholders in your business to identify where there may be a risk of “associated persons” facilitating tax evasion. This typically includes finance, procurement, HR and operational leads.
Identify those people who could risk bringing you within the scope of the CCO legislation – your Associated Persons. Identify risk areas and mitigating controls by putting yourself in the position of your associated persons to determine where they may have the ‘means, motive, or opportunity’ to facilitate tax evasion. Assess those areas which are under close scrutiny by HMRC - off-payroll workers and VAT fraud within the supply chain, being two such areas Typical areas of the business that should be involved in discussions relating to CCO include tax, legal, finance, HR, and supply chain management.
BENCHMARK
We benchmark existing risks and controls to our CCO Risk Database and develop for each of our clients a detailed CCO Risk Register identifying any gaps and potential next steps.
Sharing of CCO policy templates
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A tailored CCO eLearning module to ensure all those in your business understand their responsibilities.
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DETERMINING THE EXTENT OF POTENTIAL EXPOSURES
RISK ASSESSMENT
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