Set to come into effect tomorrow, the Criminal Finances Act 2017 received Royal Assent on 27th April 2017 and was the UK Government’s response to the “Panama Papers” scandal.
Part 3 brings about two new corporate offences, which come into effect on 30th September, of failure to prevent the facilitation of tax evasion in the UK and abroad.
The offences impose strict liability and it is for you, as a firm, to demonstrate that you have “reasonable prevention procedures” in place or to demonstrate that it is not reasonable to expect you to have any prevention procedures in place.
At Legal Eye, we pride ourselves on working with our client firms on a practical level. We ensure that our firms have policies, procedures, plans, registers, logs and all manner of other compliance-related documents in place so that they comply with what seems like a never-ending list of regulatory and accreditation requirements, thus releasing precious management and fee earning time to enable our firms to do what they do best – providing a quality legal service to their clients.
Our CFA suite of documents is no different and has been developed to enable us to assist firms on a practical level. It includes:
- CFA 2017 Policy
- CFA 2017 Firm-Wide Risk Assessment
- Implementation and Communication Plan
- Suspicious Activity Report Form
- Suspicious Activity Report Register
- Statement of Compliance for your Website
- Statement of Compliance Clause for Terms of Business
- Matter Risk Assessments
- CFA 2017 Updates for your Risk Register / Compliance Plan and compliant clauses for your associated policies.
HMRC have said there are certain steps they expect to be in place by 30th September and that firms should ensure “… rapid implementation, focusing on the major risks and priorities with a clear timeframe and implementation plan on entry into force”.
What steps have you taken?
Call Legal Eye today on 0203 0512049 or email info@legal-eye.co.uk for more information on how we can assist you to implement reasonable prevention procedures.
