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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made 30 June 2014 onwards: opening the investigation: reasons for registration not to be discussed

The letter offering the Contractual Disclosure Facility (CDF) must not indicate the reasons why the case has been registered for investigation.

If advisers query the policy, you must refer them to the Code of Practice 9 which says:

‘We will not usually tell you what our suspicions are; it is for you to decide to make a disclosure to us’.

This is because:

  1. An investigation under COP9 must give the customer an opportunity to make a full and complete disclosure of any irregularities and minimise any penalties that may be due.
  2. In some cases your main suspicion might be information from a third party, the source of which cannot be revealed to the customer.