BDO UK | CRIMINAL FINANCES ACT 2017
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PRACTICAL STEPS 2: CCO E-LEARNING
PRACTICAL STEPS 3: MONITORING AND REVIEW
Monitoring is all about the testing of adherence to your CCO procedures and underlying processes and controls that would identify where facilitation of tax evasion could occur. In many cases, this may be covered by existing internal audit or review procedures. Various events such as business transactions, expansion into new jurisdictions or business areas would also trigger a review of risks and controls.
HMRC specifically state that organisations “ should seek to ensure that its prevention policies and procedures are communicated, embedded and understood throughout the organisation, through internal and external communication, including training. ” We have developed and rolled out our CCO eLearning training across not only all our staff at BDO but for dozens of our clients across all industries (and over 10,000 people). Specifically, we see it as a way of demonstrating the right ‘culture’ within the organisation – ie that you can demonstrate you have a zero tolerance approach to tax evasion and facilitation of tax evasion. The training is always customised for the client in terms of the narrative and wording, as well as the interactive scenarios and images.
In practical terms, our clients are ensuring that CCO is embedded within their existing internal review framework (including Senior Accounting Officer, internal audit or simply peer reviews).
Similarly, CCO should be considered as part of wider ‘failure to prevent’ compliance including AML and Anti-Bribery.
Example of typical training programme
COMMUNICATION & TRAINING TYPE
AUDIENCE
Classroom based Senior management and key decision makers
eLearning training All those in the business that can influence financial transactions, e.g., HR, Finance, Procurement etc
CCO awareness and briefing (e.g. sharing of policies, email, revising contractual terms)
All suppliers (including contractors), remaining low- medium risk staff
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