According to Ogier partner Nick Williams, “…the law specifically requires top level management to be integrally engaged, and… to actively ‘foster a culture where actions intended to facilitate tax evasion are considered unacceptable’.”
The law, included in last month’s Criminal Finances Bill covers any business that deals with UK taxpayers or has a connection with the UK, and demands personal engagement in the prevention of tax evasion by top level managers.
It’s expected more sector-specific guidance will be issued before the law comes into force, but Mr Williams is advising firms to start adapting and expanding their compliance procedures.
Mr Williams adds: “this law is going to be a reality and financial services businesses need to have it firmly on their agendas. It requires specific consideration of tax evasion issues in risk assessments and due diligence checks – on this point the guidance is clear, it will not be sufficient to rely on existing procedures and checks, more will need to be done.”