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  2. Criminal Finances Act
About City

Criminal Finances Act

Tackling Tax Evasion Statement 2018-19

This statement has been published in accordance with the Criminal Finance Act 2017. It sets out the commitment of City, University of London (referred to as “City” or “The University” below) to preventing persons associated with City and its subsidiaries from engaging in the criminal facilitation of tax evasion.

Introduction

Tax evasion is when individuals or businesses deliberately omit, conceal or misrepresent information to reduce their tax liabilities.  Organisations can be used by associated individuals or businesses to facilitate taxpayer evasion in the UK or overseas.

City is committed to preventing the facilitation of tax evasion by associated individuals or businesses anywhere within its operations.  We do this through developing reasonable prevention procedures, carrying out regular due diligence and risk assessments of our activities and creating awareness and a culture of compliance throughout City.  We also use our strategic planning processes to identify possible risks for future activity, possible changes in legislation and through efficient and effective contract management.

1. Risk Assessment and Implementation of Prevention Procedures

City is committed to embedding processes which will help eliminate the opportunities for the criminal facilitation of tax evasion.

The University undertakes risk assessments to determine the nature and extent of exposure to the risk of any “associated persons” engaging in activity that could criminally facilitate tax evasion.   Reasonable prevention procedures proportionate to the size, complexity and risk are implemented.

The University maintains a register of possible risks of the facilitation of tax evasion by its staff and associates, as well as listing controls to mitigate those risks, and any actions required to improve those controls.  This register is regularly reviewed and updated, as and when required in relation to the nature of the specific risks.

2. Due Diligence

Due diligence on both customers and suppliers will be undertaken in order to ensure that the risk of potential interactions with City or its subsidiaries being used by associated persons to engage in the criminal facilitation of tax evasion is clearly identified before any transactions take place.  This due diligence will be proportionate to the identified risk.

3. Raising Awareness & Collaboration

As the strategic knowledge base for Tax at City, the Finance & Procurement Directorate is committed to staying aware of developments, legislation and case studies in regards to the prevention of the criminal facilitation of tax evasion.  Eliminating the opportunities to facilitate tax evasion effectively requires improved traceability, increased transparency and collaboration between statutory agencies, civil society organisations and both public and private sector business.

  • The University has nominated key officers responsible for information and queries on CFA2017 within City. The Key Officers for CFA 2017 are:
    • Liz Rylatt - Chief Financial Officer
    • Marion O’Hara - Deputy Chief Financial Officer
    • Andrew Younger - Head of Finance: Financial Accounting & Systems
  • Training on CFA2017 will be included within City’s Finance & Purchasing Training which is mandatory for those staff which have purchasing and financial responsibilities.
  • Targeted training and awareness raising will also be provided to those high risk areas identified as part of the Risk Assessment
  • City will work in collaboration with other universities and external bodies such as BUFDG, HMRC, and Office for Students, to share and develop best practice in due diligence, prevention procedures and the elimination of the criminal facilitation of tax evasion.
  • The University’s Chief Financial Officer is responsible for supply chain management transparency and initiatives.

Approved by the Executive Committee on 24 September 2018