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CCO investigations: had the horse already bolted?

Jason Collins and Laura Ford (DLA Piper) take stock of the corporate criminal offence in view of recent statistics showing no charges to date and just nine live investigations.

HMRC has decided to publish corporate criminal offence (CCO) (the Criminal Finances Act 2017 Part 3) statistics regularly as part of a broader campaign to tackle serious revenue crime and professional enablers as set out by the outgoing head of the Fraud Investigation Service Simon York in an interview in the Financial Times on 12 January.

The statistics paint a mixed picture. Zero charges ever nine live investigations 26 other ‘live opportunities’ under consideration 77 opportunities rejected.

To many this will not be seen as a great return on investment – and perhaps with this in mind an additional £79m of resources to help HMRC tackle serious fraud and non-compliance by the wealthy was...

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