Anti-Facilitation of Tax Evasion Policy

Reasonable prevention procedures for the Criminal Finances Act 2017 corporate offences, with a risk assessment, red flags and supplier and staff controls.

Editable Word document
15
10pages
Guidance notes included
aml consultancy solutions

Health, safety & compliance

Anti-Facilitation of Tax Evasion Policy

About this document

What it’s for

A policy and set of procedures to stop anyone working for or on behalf of your business from helping a customer, supplier, employee or anyone else to evade tax. It is designed to give you the “reasonable prevention procedures” defence to the failure to prevent offences in Part 3 of the Criminal Finances Act 2017.

When to use it

  • Every company and partnership – the offences apply whatever your size
  • Especially if you handle cash, use subcontractors, run payroll, give tax or financial advice, or trade internationally
  • When banks, customers or tenders ask for evidence of your procedures

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  1. Policy statement
  2. Scope
  3. Definitions
  4. The law in summary
  5. What you must not do
  6. Responsibilities
  7. Risk assessment
  8. Prevention procedures
  9. Due diligence
  10. Raising a concern
  11. Training and communication
  12. Breaches of this policy
  13. Records, monitoring and review

Also included

  • Approval
  • Risk rating key
  • Customers and clients
  • Suppliers, subcontractors and agents
  • Workers and payroll
  • Internal warning signs
  • Model contract clause
  • Concern report form
  • Staff acknowledgement

How to complete it

  • Complete the risk assessment in Appendix A first, honestly
  • Tailor the red flags in Appendix B to your sector
  • Name a Responsible Person and fill in the contact details
  • Train staff and keep signed acknowledgements (Appendix D)

Key points to check

  • The offences cover tax evasion, not lawful tax planning – but get advice if you sell tax-related products or services
  • Review the procedures every year and whenever you change how you operate

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

Included in the pack

Health, safety & compliance

£20

for every document in this category

Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

Download and keep

Get the packSee every document in this pack →

Need more than one category?

Documents All-Access gives you every category for 12 months for £295.

Compare options →

Need it tailored?

We can adapt any template to your business, or write a document from scratch.

Talk to us →