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The Corporate Criminal Offences (CCO)

The Corporate Criminal Offences (CCO)

The Corporate Criminal Offences (CCO) follow a growing trend towards proactive legislation that places criminal liability on companies that fail to prevent tax evasion and other forms of financial crime.


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We help clients to identify and implement reasonable procedures to prevent the facilitation of tax evasion. We have worked closely in this space with retail, private and investment banks, insurance companies, asset managers and global and UK based corporates.

The offences bear key similarities with the Bribery Act 2010, particularly in respect of the available corporate defence if wrongdoing is identified.

Our combined team of tax, risk consulting and legal services specialists have in-depth knowledge of the Corporate Criminal Offences.

We can work with you proactively to help put in place reasonable procedures, or reactively to help you respond to regulatory or investigative action. Our core solutions include:

Risk assessment, control analysis and implementation: Identify the risks of tax evasion facilitation across your organisation, assess the suitability of your existing control framework and implement necessary additional controls.

Communication and training: Use the latest methods and technology to train staff and help ensure key messages are understood and adopted.

Governance and culture: Develop a strong and effective governance framework that engages staff and works for your business.

Monitoring and testing: Harness technology to help protect your business and provide assurance that your risk controls are operating effectively.

Enforcement, remediation and disclosure: Respond to disputes or litigation proactively to work towards a positive outcome and mitigate disruption to your organisation.

The team is led by Annabel Reoch, a Forensic partner with significant experience of both the CCO and the Bribery Act 2010, and Chris Davidson, a Tax director with over 40 years of experience in tax administration, including 37 years at HMRC. Annabel is also UK Head of ABC, while Chris engages with HMRC on a regular basis in respect of proactive tax-dispute resolution.

Annabel and Chris lead a team comprised of tax and risk consulting specialists supported where required by our legal services specialists.

Our established methodology can help you implement sustainable preventative procedures, demonstrate an understanding of the legislation and embed compliance with the Corporate Criminal Offences into your existing framework.

Examples of our work

Global Financial Institution with head office outside the UK

• Global CCO risk assessment

A global financial institution required support in conducting a CCO risk assessment across all jurisdictions and business areas. KPMG worked with the client to develop the organisation’s risk assessment approach in alignment with their existing approach to financial crime, manage the risk assessment activity, report on progress and prepare a targeted action plan to implement required controls.

KPMG provided UK and overseas staff with relevant local knowledge of tax and financial crime legislation. This improved the output of the risk assessment and helped with the identification of any additional required controls.

Global Investment Manager

• Establishing CCO programme

A global investment manager with a branch in the UK required support to establish their CCO programme. KPMG facilitated workshops with key stakeholders to develop a preliminary view of risks across the group and developed a high-level compliance roadmap, utilizing subject matter experts from Tax and Financial Crime.

Global Financial Institution with branch in UK

• UK Risk Assessment

A global financial institution needed support to conduct a risk assessment of their UK branch. KPMG developed a methodology for assessing the UK branch’s CCO risk, facilitated risk assessment workshops and produced a gap analysis report and implementation plan. KPMG were able to rapidly deploy subject matter experts with prior experience working on tax evasion related issues at HMRC. This allowed the client to effectively identify facilitation risks and implement required controls in readiness for the organisation’s internal deadline.

Global Corporate

• Conducting a CCO health-check

A global corporate required support to conduct a CCO health-check. KPMG reviewed the entity’s approach, methodology and CCO risk assessment activity undertaken to date. We then prepared a progress report and assisted the client in the preparation of an implementation plan, leveraging our experience working with other comparable organisations. 

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