Corporate Criminal Offence (CCO) – are you compliant?

What is the CCO?

The Corporate Criminal Offence (CCO) is a regulation that applies to all companies, no matter their size or industry. Introduced under the Criminal Finances Act 2017, it requires businesses to take reasonable steps to prevent their employees or associates from helping others evade tax.

Why is this important? Non-compliance can lead to severe penalties, including unlimited fines and significant damage to your company’s reputation.

Latest statistics from HMRC

According to these latest statistics, there are 11 live CCO investigations. In addition, there has been an increase in the number of opportunities under review. HMRC report they have reviewed and rejected 114 opportunities, highlighting an increased focus on CCO enforcement. In our experience, CCO compliance is becoming a more important part of HRMCs business risk review conversations and frequently comes up as part of the due diligence process.

New legislation on fraud prevention

The Economic Crime and Corporate Transparency Act 2023 which comes into effect from 1 September 2025, introduces a new corporate criminal offence of failure to prevent fraud. This legislation aims to hold large organisations accountable if they profit from fraud committed by their employees or associates. This means directors need to ensure their business has adequate fraud prevention measure in place or the company may face criminal liability.

The future of CCO

Companies need to make compliance a top priority to avoid any negative consequences. With regulatory scrutiny on the rise, businesses must stay alert and take proactive steps to prevent tax evasion and fraud.

Supporting our clients to be compliant

Our experts, with in-house and HMRC experience, understand the complexities of CCO compliance. They assist our clients navigate these regulations effectively by:

• Conducting thorough risk assessments to identify potential areas of vulnerability within their organisation
• Assisting in developing and implementing robust policies and procedures to prevent the facilitation of tax evasion
• Providing tailored training programs to ensure that your employees are aware of their responsibilities under the CCO

By working with us, you can be confident that your business is taking the necessary steps to comply with CCO regulations and avoid the penalties associated with non-compliance.