Criminal Finances Act 2017 Policy Statement

Our commitment to preventing the facilitation of tax evasion, and the procedures we maintain to detect and prevent it.

Version 1.0   ·   Last updated: June 2026   ·   Owner: Senior Management

Purpose and scope

This policy sets out the approach of MJP Conveyancing Limited to preventing the facilitation of tax evasion, and explains our responsibilities under the Criminal Finances Act 2017. It applies to all of our business dealings and in every country in which we operate.

This policy applies to all persons working for us, or on our behalf, in any capacity. This includes directors, employees, consultants, contractors, trainees, agents, and any other person associated with us. In this policy we refer to all of these people as our personnel. We also expect the standards set out in this policy to be reflected in our dealings with the third parties with whom we contract.

Our commitment

As a firm, we value our reputation for ethical behaviour and for financial probity and reliability. We recognise that, over and above the commission of any criminal offence, any involvement in the facilitation of tax evasion would also reflect adversely on our reputation.

We do not tolerate tax evasion, or its facilitation, in any circumstances, whether committed or facilitated by a client, a director or employee, or any business with which we contract.

We are committed to acting professionally, fairly, and with integrity in all of our business dealings, and to maintaining rigorous procedures to detect and prevent the facilitation of tax evasion offences.

The law

The Criminal Finances Act 2017 introduced two corporate offences of failing to prevent the criminal facilitation of tax evasion: the failure to prevent the facilitation of UK tax evasion under section 45, and the failure to prevent the facilitation of foreign tax evasion under section 46.

A business may be criminally liable where a person acting on its behalf criminally facilitates tax evasion by another person, even where the senior management of the business was not involved in, and was not aware of, what was happening. It is a defence for the business to show that it had reasonable prevention procedures in place, or that it was not reasonable in the circumstances to expect such procedures.

This policy, together with our wider compliance and anti money laundering procedures, forms part of the reasonable prevention procedures that we maintain.

What we mean by tax evasion and facilitation

Tax evasion means cheating the public revenue, or fraudulently evading UK or foreign tax, and is a criminal offence. It involves dishonest conduct. Tax evasion is not the same as legitimate tax planning, which is lawful.

Facilitation of tax evasion means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax by another person, or aiding, abetting, counselling, or procuring that conduct. For the corporate offence to apply, the facilitation must itself be a deliberate and dishonest criminal act. Accidental, ignorant, or merely negligent involvement is not caught by the offence, although we still require the highest standards of conduct from our personnel at all times.

Our prevention procedures

Our procedures follow the guiding principles published by HM Revenue and Customs for the corporate offences. They are proportionate to the risk that we face as a provider of residential conveyancing services.

Risk assessment

We assess the risk that persons associated with us might criminally facilitate tax evasion, taking account of the nature of our work, our clients, and the third parties with whom we deal. We keep that assessment under regular review.

Top level commitment

Our senior management is committed to preventing the facilitation of tax evasion and to fostering a culture in which it is never acceptable. Senior management leads by example and supports our personnel in applying this policy.

Due diligence on third parties

We undertake due diligence on the third parties with which we contract in order to mitigate the risk of the facilitation of tax evasion offences. As part of our due diligence procedures, all agreements with third parties contain suitable provisions that enable us to terminate those agreements where the third party is not complying with the Criminal Finances Act 2017. We will always ask the third parties with which we contract to provide us with a copy of their own Criminal Finances Act policy.

Communication and training

We provide regular training to all of our personnel on the requirements of the Criminal Finances Act 2017, and on how to recognise and respond to the risk of the facilitation of tax evasion. We require all personnel to demonstrate the highest standards of honesty at all times. This policy is communicated to all personnel and is made available to the third parties with whom we work.

Monitoring and review

We monitor the effectiveness of our prevention procedures and review them regularly, and in any event whenever there is a material change in our business or in the law. Our personnel are encouraged to offer their views on how these procedures might be improved.

Responsibilities

Senior management has overall responsibility for this policy and for ensuring that it complies with our legal and regulatory obligations. Day to day responsibility for implementing the policy, and for monitoring its use and effectiveness, rests with our nominated officer for compliance.

All personnel are responsible for reading, understanding, and complying with this policy. Every member of our personnel must avoid any activity that might lead, or appear to lead, to a breach of the Criminal Finances Act 2017, and must report any concern promptly in accordance with the section below.

Raising a concern

If you become aware of, or suspect, any actual or potential facilitation of tax evasion, whether by a colleague, a client, or a third party, you must report it promptly. We will support anyone who raises a genuine concern in good faith, and no member of our personnel will suffer any detrimental treatment as a result of raising such a concern. A report of this kind may also engage our anti money laundering and whistleblowing procedures.

Consequences of a breach

Any member of our personnel found to have been involved in tax evasion, or in its facilitation, will face disciplinary action, which may include dismissal for gross misconduct. We may also terminate our relationship with any third party that breaches the Criminal Finances Act 2017. The facilitation of tax evasion is a criminal offence that may result in prosecution of the individuals involved and of the firm.

Review and document control

This policy is reviewed regularly and updated as necessary. Any questions about its content should be directed to senior management.

Owner: Senior Management        Version: 1.0        Last reviewed: June 2026        Next review due: June 2027