Settling the enquiry: general: Publishing Details of Deliberate Defaulters - disclosure and cooperation
When considering whether to publish the details of the customer under Publishing Details of Deliberate Defaulters (PDDD) at the settlement stage of the investigation, you must take into account the amount of penalty reduction for the quality of their disclosure and cooperation. See CH500200.
Unless a full disclosure of all irregularities is made at the first opportunity and the maximum penalty reduction is given for a deliberate penalty, the customer must be considered for the PDDD programme.
In a case where you have taken over a compliance check or investigation, you must take into account the quality of the disclosure and the amount of cooperation from the start of the original compliance check (or investigation) to the end of your investigation, when calculating the penalty and assessing the PDDD position. The customer may have already lost the opportunity to make a fully unprompted disclosure before you start your investigation.
You must also consider PDDD at your initial meeting with the customer as they can lose the opportunity to gain maximum penalty reduction if you have to prompt them into disclosing any deliberate behaviour.