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CCO investigations: had the horse already bolted?

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Statistics published by HMRC show zero charges and just nine live investigations of the ‘corporate criminal offence’. Is this a ‘failure’? HMRC says not as behaviours have changed, but £79m has been pledged to beef up this area. The offence was a response to criticism that no Swiss banks were prosecuted for helping to hide customer assets, but by that time banking secrecy had ended anyway. Where are the other typologies of facilitation?
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