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An Anti-Facilitation of Tax Evasion Policy outlines how an organization prevents its staff and partners from helping others dodge their tax obligations. It's a key requirement for NZ businesses, especially those working internationally or handling significant financial transactions.

The policy sets clear rules about spotting and reporting suspicious activities, training requirements for staff, and consequences for breaking these rules. It helps organizations comply with local tax laws and criminal legislation while protecting themselves from legal risks. Many Kiwi businesses use this policy alongside their broader anti-money laundering programs.

Implement an Anti-Facilitation of Tax Evasion Policy when your organization operates across borders, handles large financial transactions, or works with multiple business partners. This policy becomes essential for NZ companies expanding internationally or those in high-risk sectors like financial services, consulting, or property development.

The policy proves particularly valuable during mergers and acquisitions, when onboarding new business partners, or setting up overseas operations. It's also crucial when your organization faces increased regulatory scrutiny or needs to demonstrate robust compliance systems to stakeholders, investors, or banking partners.

• Basic policy for small businesses: Focuses on essential prevention measures, staff training requirements, and basic reporting procedures
• Comprehensive corporate version: Includes detailed risk assessment frameworks, complex due diligence procedures, and international compliance measures
• Financial services adaptation: Features enhanced customer screening, transaction monitoring, and specific red flag indicators
• Professional services variant: Emphasizes client engagement protocols, cross-border service provisions, and professional obligation clauses
• Group-wide policy: Covers multiple entities, subsidiaries, and complex organizational structures with unified reporting systems

• Board Members: Approve and oversee the policy, ensuring it aligns with corporate governance and risk management strategies
• Compliance Officers: Draft, implement, and monitor the policy, conducting regular reviews and updates
• Legal Teams: Review policy content, ensure alignment with NZ tax laws, and advise on enforcement measures
• Department Managers: Train staff, implement procedures, and report potential violations
• External Partners: Must understand and comply with policy requirements when engaging with the organization
• Staff Members: Follow policy guidelines in daily operations and report suspicious activities

• Risk Assessment: Map your organization's tax evasion risks across different business activities and jurisdictions
• Current Processes: Document existing procedures for financial transactions, partner due diligence, and reporting
• Legal Framework: Review NZ tax laws and international obligations affecting your operations
• Staff Structure: Identify key roles and responsibilities for policy implementation and oversight
• Training Needs: Plan how staff will learn about and apply the policy effectively
• Reporting Systems: Establish clear channels for raising concerns and tracking compliance
• Review Schedule: Set regular policy review dates and update triggers

• Policy Purpose: Clear statement of commitment to preventing tax evasion facilitation
• Scope Definition: Detailed coverage of activities, jurisdictions, and affected parties
• Risk Assessment: Framework for identifying and evaluating tax evasion risks
• Due Diligence: Procedures for vetting business partners and transactions
• Reporting Mechanisms: Clear processes for raising concerns and whistleblower protection
• Training Requirements: Mandatory staff education and awareness programs
• Compliance Monitoring: Methods for tracking and reviewing policy effectiveness
• Enforcement Measures: Consequences for policy breaches and disciplinary procedures

While both focus on ethical business conduct, an Anti-Facilitation of Tax Evasion Policy differs significantly from a Compliance and Ethics Policy. The key distinctions lie in their scope, specific requirements, and implementation approaches.

• Focus and Scope: Tax evasion policies specifically target financial crime prevention, while compliance and ethics policies cover broader ethical business conduct
• Legal Requirements: Tax evasion policies directly address tax law obligations and criminal liability, whereas ethics policies typically cover general regulatory compliance
• Risk Assessment: Tax evasion policies require specific financial transaction monitoring and red flags, while ethics policies focus on broader organizational risks
• Training Content: Tax evasion training emphasizes financial crime detection and reporting, compared to general ethical decision-making in compliance policies
• Enforcement Mechanisms: Tax evasion policies include specific procedures for suspicious activity reporting, while ethics policies often use broader disciplinary frameworks