CRIMINAL FINANCE ACT – 2017
The Criminal Finances Act 2017 (c. 22) (“CFA”) is an Act of the Parliament of the United Kingdom
that amends the Proceeds of Crime Act 2002 to expand the provisions for confiscating funds to deal
with terrorist property and proceeds of tax evasion. The Act received Royal Assent on 27 April
2017. For more details – Criminal Finances Act 2017 (legislation.gov.uk)
This note outlines our responsibilities under the CFA, which came into force in 2017.
The CFA was passed to ensure companies in the UK take reasonable prevention procedures to prevent
the facilitation of tax evasion either in the UK or abroad.
Overarching approach
We are committed to preventing the criminal facilitation of tax evasion. This commitment extends to
anyone acting on our behalf.
Risk Assessment
Due to the nature of our business, the risks are considered to be low but have been identified as:
i. receiving an overpayment into our account, and being asked to refund it, thereby ‘cleaning’ the
money;
ii. being asked by a supplier to pay in cash, knowing or reasonably knowing that their intension
is not to declare the receipt for VAT or other reasons; and
iii. employees receiving money direct from a company, using personal bank accounts.
These risks are mitigated through a number of things including the tasks set forth below:
• employing appropriately skilled staff with appropriate oversight by management.
• ensuring that all Directors can monitor bank accounts, in addition to the Financial
Controller.
• we have a financial review system in place for all bank transfers / use of
mastercard’s.
• employees agreement that no monies will be sent via their own private accounts from any of our
Clients, nor any cash to be accepted.
• on employment, ensure all employees provide valid copies of their passports, and their UK bank
account details.
• communicating clearly to staff that we are committed to preventing the facilitation of tax
evasion.
• the monitoring and enforcement of staff procedures.
• the monitoring and enforcement of prevention procedures.
• only accepting payments using company bank transfers/mastercards and ensuring all cash payments
are declined in order to mitigate any risks of potential facilitation of tax evasion. Regular
reviews of procedures.
• ensuring all Directors and employees take one 2-week uninterrupted holiday per year.
• ensuring a thorough check on new Clients is undertaken, including:
o Search on Companies House
o Search internet / press for any corruption news
o Ensuring we have a signed engagement contract
o Noting how we know the Client
o All new clients require approval of two directors who will decide if any additional checks will
be required, which would be undertaken by an entity specialised on this matter.
• ensuring all invoices are thoroughly reviewed by a Director and signed off.
• employees are made aware of the whistle blowing policy should they ever need it (see INDECS
Employee Handbook)• employees to sign a recognition form with respect to this Act and whistleblowing.
• training provided to all existing / new members with an annual refresher.
Further Detail
The CFA and practice and procedures may develop over time. Our auditors may advise on different or
further steps which may or should be taken. Such advice, or information which we see in our
professional reading, will be taken into account in a way consistent with our wish to operate to
high standards.
We will consider and take appropriate advice on what if any ‘whistle blowing’ is required should we
have any concerns of suspected facilitation.
Commencement Date
This policy is implemented with immediate effect.
Review Date
This policy will be reviewed annually. If we become aware of formal guidance or guidelines being
published at any time, the policy will be reviewed within a reasonable timeframe thereafter.
