Failure to prevent facilitation of tax evasion: are your procedures in place?

With just a few weeks to spare before the Criminal Finances Act 2017 (CFA) offence of failure to prevent the criminal facilitation of tax evasion took effect on 30 September, the Chancellor of the Exchequer, through the Facilitation of Tax Evasion Offences (Guidance about Prevention) Regulations 2017, confirmed the HMRC guidance (the Guidance), updated on 1 September, would take effect on the same date as the offence.