Corporate Criminal Offence Guidance


The Association of Foreign Banks has worked in conjunction with other financial services trade bodies to produce industry guidance on the ‘corporate criminal Offence: failure to prevent tax evasion’ requirements, originally proposed in the Criminal Finances Act 2017.

Under the requirements, companies and partnerships with a UK nexus are now criminally liable if they fail to prevent tax evasion by either a member of their staff or an external agent.

Firms will have a defence of having put in place reasonable procedures if the organisation has done as much as it can reasonably be expected to do to address the risk that its respective associated person ignores the organisation’s policies against being complicit in financial crime, and seeking to evade the firm’s procedures in these areas.


The Guidance was approved on 8th January 2018 by the Chancellor, and is available to download below: 



If you would like any further information then please contact Bruk Woldegabreil, Director, AFB, in the first instance: