In recent years, we have seen a seismic shift globally towards offences aimed at combatting corruption, fraud, tax evasion and money laundering. The UK’s new corporate criminal offence of the failure to prevent the facilitation of tax evasion (the “CCO”), which entered into force on 30 September 2017, is yet another targeted tool being employed by the UK government and Her Majesty’s Revenue & Customs (“HMRC”) to bolster existing anti-bribery, corruption and money laundering offences.…