A 45-minute, CPD-assessed course on the corporate offence of failing to prevent the facilitation of tax evasion: where evasion ends and avoidance begins, who counts as acting for the firm, what a request to help looks like, and what to do. Rewritten for 2026, and scheduled, chased and certified for you.
Staff who cannot tell them apart either escalate every aggressive structure or escalate nothing. The hinge is dishonesty and concealment, not whether somebody wants to pay less tax.
Using reliefs and allowances the way they were meant to be used. Nothing to report.
An arrangement argued in the open that HMRC may challenge. Not criminal in itself, though it can carry real consequences, and the Finance Act 2026 adds a criminal offence for a promoter who fails to notify a scheme.
Dishonestly not paying tax that is due, usually by concealment. A crime, and helping somebody do it is a crime too, whether or not you gained anything.
Written for the desk where these requests actually arrive: onboarding, payments, billing, reporting and introductions.
Three things that get run together, and the question that separates them: does it depend on a tax authority not being told? What evasion actually looks like in this business, the corporate offences that put the firm at risk, the offence an individual can commit themselves, what a conviction does to a firm, and how this sits with the newer failure to prevent fraud offence.
Why “associated person” is a much wider net than “employee”, what facilitation actually looks like, where it turns up in an ordinary week, contractors and umbrella companies, and what is not a red flag. Includes a filmed scenario.
Due diligence on the people who act for us, what a good file looks like, what “reasonable” means in a firm of twenty people, and where procedures are usually thin.
Reporting internally and early, why a tax suspicion usually becomes a money laundering report too, why your note matters, what goes in the report, what reporting protects you from, and why things sometimes go quiet afterwards.
What is expected of you, senior managers and the 2026 change to corporate liability, what an investigation actually looks like, telling HMRC first, and what the record has to show.
The foreign tax evasion offence, what the authorities can already see, cryptoasset reporting from January 2026, what actually makes a jurisdiction higher risk for tax, and why third parties are where these offences were aimed.
What to take away and three things to do this week, followed by the test and the certificate.
Facilitation rarely looks like a crime when it reaches a desk. It arrives as an administrative preference. By the end, a learner can:
A short film, shot for Fundsure with the same cast across the catalogue, puts the learner beside a colleague asked to handle a client’s payment whose real purpose is unclear. The learner chooses what she should do, and is told why the tempting answers are wrong: asking the client what the payment is really for, processing it with a note on the file, or declining politely and mentioning it to nobody.
The test at the end draws 10 questions from a bank of 30, with a pass mark of 80%, and a pass issues a named, CPD-marked certificate that anyone can check online.
Checked against HMRC's guidance and the legislation in force. Last checked Sept 2026.
HMRC brought its first corporate prosecution under the UK offence on 11-Aug-25, against an accountancy firm and six individuals. The case is unresolved and the course does not assume an outcome.
In force 29-Jun-26. Where a senior manager commits an offence within the scope of their authority it can be attributed to the organisation, with no reasonable procedures defence. “It was signed off upstairs” is now worth much less.
Being knowingly concerned in the fraudulent evasion of tax by any other person is an offence in its own right. The firm's defence protects the firm, not the person who helped.
From April 2026 responsibility for PAYE through an umbrella company sits with the agency, or the end client where there is none. Who runs a contractor's payroll is now a due diligence question.
The Cryptoasset Reporting Framework has applied in the UK since 01-Jan-26. A client who believes crypto holdings are outside the reporting net is working from an out-of-date position.
In force since 01-Sept-25 and taught alongside the tax offences, because firms conflate them: the fraud offence needs an intention to benefit and applies only to large organisations. The tax offences need neither.
Under the Criminal Finances Act 2017 the only defence to failing to prevent the facilitation of tax evasion is that the firm had reasonable prevention procedures. HMRC’s guidance sets out six principles: risk assessment, proportionality, top-level commitment, due diligence, communication including training, and monitoring and review.
A procedure nobody can evidence is not a defence. In the Fundsure Portal every sitting, score and certificate is kept and carried into the compliance officer’s report to the board.
How the portal runs trainingAnti-Tax Evasion Awareness plus AML and CTF, anti-bribery, sanctions, Conduct Rules and the rest of the catalogue of 20, with no per-course fees.
Evaded tax is criminal property, so a tax suspicion is usually a money laundering report too.
See the courseThe other failure to prevent offence, and the same associated person idea.
See the courseSanctions as prohibitions: freeze first, then escalate and report.
See the courseFor trust and company service providers, where structures and nominees meet tax risk most directly.
See the courseWe will send you a link to take the whole course, filmed scenario and test included, or walk you through the portal with a demonstration firm.
