BDO UK | CRIMINAL FINANCES ACT 2017
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DEVELOPING YOUR CCO DEFENCE IMPLEMENTING DEFENCES
PROPORTIONALITY OF REASONABLE PROCEDURES:
COMMUNICATION AND TRAINING - TOP LEVEL COMMITMENT: develop an overarching CCO Policy or tone from the top in how you are meeting this legislation communicate policies and to your “associated persons” raising awareness both within and outside the business establish a risk based CCO training program, to incorporate CCO classroom and eLearning training. monitor and review is focused on evaluating the extent to which internal controls are operating as intended carry out testing to establish how widely procedures are known within the organisation and whether they are being implemented effectively undertake your CCO risk assessment on a periodic basis ensure whistle-blower and escalation policies are procedures are embedded within the business and work as intended. MONITORING AND REVIEW:
Based on the outcome of a risk assessment, organisations are typically implementing or enhancing the following prevention procedures to align to the six key defence principles outlined in HMRC guidance.
review your policies and procedures in relation to the facilitation of tax evasion and in the context of the nature, scale and complexity of your business (bearing in mind factors such as sector risk, geographic risk, customer risk and business partnership risk) prioritise areas of weakness and develop a detailed implementation plan to address these areas. it is a vitally important aspect of your prevention programme and due diligence procedures that you identify your “associated persons" and are aware of any risks that they may facilitate tax evasion for many of your material suppliers and all associated persons that provide services for or on your behalf, we would expect a requirement for statements of compliance to CCO legislation, CCO specific contractual clauses and the right to review policies or CCO procedures as appropriate.
DUE DILIGENCE:
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DEMONSTRATING REASONABLE PREVENTION PROCEDURES
PROPORTIONALITY OF REASONABLE PROCEDURES
TOP LEVEL COMMITMENT
COMMUNICATION AND TRAINING
MONITORING AND REVIEW
DUE DILIGENCE
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