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An Anti-Facilitation of Tax Evasion Policy helps organizations prevent their staff and partners from helping others dodge taxes illegally. It's a key requirement under the UK's Criminal Finances Act 2017, which makes companies responsible when their employees or associates help someone evade tax.

The policy sets out clear rules and procedures to spot and stop tax evasion risks. It typically includes staff training, due diligence checks on business partners, and reporting procedures for suspicious activity. Having this policy, along with proper controls, can protect organizations from criminal charges if someone associated with them tries to facilitate tax evasion.

Put an Anti-Facilitation of Tax Evasion Policy in place when your organization works with contractors, suppliers, or other third parties who handle financial transactions. This is especially important for businesses in high-risk sectors like financial services, construction, or international trade.

The policy becomes essential when onboarding new business partners, opening overseas operations, or restructuring your company. It's also crucial if your staff manage client funds, provide tax advice, or handle cross-border payments. Remember: under the Criminal Finances Act 2017, UK organizations need these controls in place before problems arise—waiting until after a tax evasion incident is too late.

• Basic Policy: Focuses on core prevention measures and reporting procedures. Ideal for small businesses with straightforward operations.
• Comprehensive Policy: Includes detailed risk assessment frameworks, extensive training requirements, and complex due diligence procedures. Suited for large corporations or financial institutions.
• Industry-Specific Policy: Tailored to high-risk sectors like construction or professional services, with specific examples and controls relevant to common industry scenarios.
• Group-Wide Policy: Designed for corporate groups with multiple entities, covering inter-company transactions and shared responsibility structures.
• International Operations Policy: Enhanced controls for businesses with overseas operations, addressing cross-border risks and country-specific requirements.

• Board Members: Must approve and oversee the Anti-Facilitation of Tax Evasion Policy, ensuring it aligns with corporate strategy and risk appetite.
• Compliance Officers: Lead the policy's implementation, monitor adherence, and update procedures based on regulatory changes.
• Finance Teams: Apply the policy daily when processing transactions and maintaining financial records.
• HR Departments: Handle staff training, awareness programs, and integrate policy requirements into employment contracts.
• External Partners: Must understand and comply with the policy when conducting business with the organization.
• Legal Advisers: Review and update the policy to ensure it meets current legislative requirements.

• Risk Assessment: Map out your organization's key tax evasion risks, including international operations and high-risk business relationships.
• Current Controls: Document existing financial procedures, due diligence processes, and reporting mechanisms.
• Staff Roles: Define responsibilities for policy implementation, monitoring, and reporting across all departments.
• Training Needs: Identify required staff training programs and awareness materials.
• Reporting Lines: Establish clear channels for raising concerns and escalating suspicious activities.
• Review Schedule: Set up regular policy review dates and triggers for updates based on business changes or new regulations.

• Policy Statement: Clear commitment to preventing tax evasion and legal compliance under Criminal Finances Act 2017.
• Scope Definition: Who the policy applies to, including employees, contractors, and business partners.
• Risk Assessment Framework: Methods for identifying and evaluating tax evasion risks.
• Due Diligence Procedures: Steps for vetting new business relationships and transactions.
• Reporting Mechanisms: Clear procedures for reporting suspicious activities and whistleblowing protection.
• Training Requirements: Mandatory staff training programs and awareness initiatives.
• Consequences: Disciplinary measures for policy violations and legal implications.

While both policies address corporate integrity, an Anti-Facilitation of Tax Evasion Policy differs significantly from an Anti Bribery and Corruption Policy. Here are the key distinctions:

• Legal Framework: Tax evasion policies specifically address the Criminal Finances Act 2017, while anti-bribery policies focus on the Bribery Act 2010.
• Risk Focus: Tax evasion policies target financial transactions and tax-related activities, whereas anti-bribery policies address improper payments and business advantages.
• Compliance Measures: Tax evasion controls emphasize transaction monitoring and tax compliance, while anti-bribery measures focus on gifts, hospitality, and business relationship management.
• Reporting Requirements: Tax evasion policies require specific HMRC-related reporting procedures, while anti-bribery policies often involve broader corporate governance reporting channels.