What do I do if a business is in breach of a direction under Schedule 7 Counter- Terrorism Act 2008?
A failure by a business to have systems and procedures in place to identify transactions or customers so that it can comply with directions under CTA 2008 is similar to a breach of the Money Laundering Regulations and should be treated in the same way ( warned and then penalised if corrective measures have not been put in place).
If however you discover that a business has failed to comply with a direction it is a serious matter as a criminal offence has been committed. The course of action that we would take would depend on the severity of the failure to comply. The matter should be referred to the Policy Team to consider whether HMRC should deal with it making use of civil penalties or to report it to the appropriate prosecuting authority for a decision to be made regarding prosecution.