This statement comprises the policy of the Company (“we”) towards our responsibilities under the Criminal Finances Act 2017. The Act was passed on 27th April 2017 and came into force on 30th September 2017.

Policy Overview

In line with all companies in the UK, we are required to take reasonable prevention procedures to prevent the facilitation of tax evasion either in the UK or abroad.

We are committed to taking reasonable steps to prevent involvement in the criminal facilitation of tax evasion. The commitment extends to anyone acting on our behalf.

Policy Risks

Due to the nature of what we do, the risks are considered to be low. The main risks are presently thought to be:

  • Being asked to refund an overpayment that has come into our account, thereby ‘cleaning’ the money
  • Possibly being asked by a supplier/client to pay in cash, knowing or reasonably knowing that their intention is not to declare the receipt for VAT or other reasons.
  • Employees accepting incentive payments and not declaring any tax and NI due.
  • Employees accepting incentive payments to refer contractors to tax evasion schemes.

Risk Mitigation

  1. Risk Assessment
    Identify the risks that may enable facilitation of tax evasion and put measures in place to stop these. Payments to only be accepted by BACS to mitigate risks.
  2. Due Diligence
    Conduct Due Diligence on our supply chain and PSL list. Identify any areas where facilitation could take place and address these.
  3. Communication and Training
    Communicating the policy clearly to staff at induction and on a regular basis to ensure understanding. Ongoing training for staff to ensure minimal opportunity for facilitation.
  4. Monitoring and Review
    The Criminal Finances Act 2017 is only a few years old, and practice and procedures could develop in the future. Our auditors, legal or tax advisors may advise on different or further steps which should be taken. Such advice, or information will be considered in a way consistent with our high standards.

Should we have any concerns of suspected facilitation, we will consider and take appropriate advice on what action is required.

Commencement date

This policy is implemented with immediate effect.

Review date

The policy will be reviewed annually. If we become aware of formal guidance or guidelines being published at any time, the policy will be reviewed within a reasonable time frame thereafter.


Undertaking correct procedures, following guiding principles and being vigilant will help to prevent Tax Evasion. Ignorance is not a defence. Doing nothing is not an option.

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