UK Failure to Prevent the Facilitation of Tax Evasion: Incident Response Checklist
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Precedents
1 Assemble an incident team
Form a tax evasion facilitation incident team without delay, bringing together your head of legal/compliance, nominated officer, risk manager and head of HR. Designate one person to chair and direct the team.
2 Consider reporting obligations
Seek legal advice before opting to self-report to HMRC. Rapid self-reporting of a tax evasion facilitation incident does not assure immunity from prosecution, but it can:
- assist your defence where there is liability for the failure-to-prevent offence;
- be considered by prosecutors when deciding whether to bring a case; and
- be reflected in any penalties if the organisation is convicted.
Also assess whether a suspicious activity report (SAR) should be submitted to the National Crime Agency...
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Web page updated on 22/05/2026
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