Corporate Criminal Offence (CCO)

Businesses operating in the UK are subject to the corporate criminal offence of failure to prevent the facilitation of tax evasion. The regime applies to both UK and foreign tax evasion and can extend across international group structures, including where non‑UK entities or third parties act on behalf of UK businesses.

The offence imposes strict liability. A business may be criminally liable if an associated person, including an employee, agent or contractor, facilitates tax evasion, unless the business can demonstrate that it had reasonable prevention procedures in place. Failure to comply can result in criminal prosecution, unlimited financial penalties and significant reputational damage.

CCO risk arises across a wide range of business activities, particularly where there is reliance on third parties, complex supply chains, cross‑border transactions or activities involving payments, advisory services or customer funds. In practice, exposure often turns on how services are delivered, how relationships are structured and the effectiveness of underlying controls.

We advise clients on CCO risk, compliance and investigations, helping them assess exposure, implement defensible procedures and respond to HMRC scrutiny.

Our CCO work

We support clients across the full lifecycle of CCO compliance and enforcement, including:

• organisational CCO risk assessments;
• design and implementation of reasonable prevention procedures;
• policy drafting and governance frameworks;
• third‑party and supply chain risk analysis;
• integration with AML, KYC and wider compliance controls;
• staff training and awareness programmes;
• HMRC enquiries and investigations; and
• self‑reporting and remediation.

Our work is typically undertaken where there is material exposure, regulatory scrutiny or a need to strengthen existing frameworks. This includes large and international groups where CCO risk extends across multiple entities and jurisdictions.

Our approach

Our approach is structured and risk‑based, designed to produce a defensible outcome.

We begin with an organisational risk assessment, identifying where and how facilitation risk arises across the business, including interactions between group entities and third parties. This includes consideration of cross‑border structures, intra‑group services and the role of associated persons.

We then assess existing controls, including AML and KYC procedures, to determine whether they can be relied upon as part of a defence to the offence. Where gaps are identified, we design and implement proportionate prevention procedures aligned with HMRC guidance and the specific risk profile of the business.

Our work is supported by structured risk frameworks and standardised methodologies designed to ensure consistency, proportionality and a clear audit trail to regulators.

When we are instructed

We are typically instructed where:

• a business has not undertaken a formal CCO risk assessment;
• existing policies and procedures require review or redesign;
• there is concern about exposure arising from third‑party relationships or international operations;
• issues have been identified through internal audit or compliance review; or
• HMRC has opened, or is expected to open, an enquiry or investigation.

How we help

We assist clients with:

• assessing exposure under the CCO regime;
• scoping entities and activities within international groups;
• designing and implementing reasonable prevention procedures;
• reviewing and enhancing existing compliance frameworks;
• advising on governance, ownership and accountability;
• managing HMRC enquiries and investigations;
• self‑reporting, remediation and stakeholder communication; and
• training staff and associated persons on identifying and preventing facilitation risk.

Contact us

If you are assessing your exposure to the corporate criminal offence, or want to review your procedures and controls, we can help you determine the appropriate approach. Please contact us to discuss.