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New corporate criminal offence: what will an investigation look like?

Large companies should refresh their raids and critical incident procedures in the event that HMRC decides to investigate, writes Jason Collins (Pinsent Masons).
 

HMRC has recently publicised a series of its high profile criminal investigations into high profile companies. This represents a huge change in strategy from the one which has been in play for the last ten years. Those groups familiar with the new corporate criminal offence in Part 3 of the Criminal Finances Act (CFA) 2017 will be busy considering or carrying out a risk assessment and thinking about ‘reasonable prevention procedures’. But are they thinking about how they would respond if HMRC were to swoop in and investigate? And how soon after the law goes live (probably in September) will those investigations begin?

Change in strategy

Before the recent activity the last publicly known criminal investigation by HMRC into a large company was probably that...

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