Update on HMRC’s Criminal Investigation Strategy & New Whistleblowing Initiative
Michael Goodwin KC joined Michelle Sloane (Partner at RPC) and Stuart Lucas (Head of Strategic Operations, HMRC’s Fraud Investigation Service) to discuss HMRC’s Criminal Investigation Strategy & New Whistleblowing Initiative.
The Panel discussion explored HMRC’s significant pressure from the government to increase the tax take. Against this backdrop, we discussed HMRC’s evolving criminal investigation strategy, and explored the latest position regarding the corporate criminal offence of failure to prevent tax evasion (CCO), and looked at how the introduction of the Economic Crime and Corporate Transparency Act (ECCTA), which came into force on 1 September 2025, is influencing HMRC’s approach. We then turned to consider HMRC’s new whistleblowing initiative, exploring practical implications for corporates, advisors, and individuals.
Delegates gained a valuable insights into emerging enforcement priorities, the interplay between CCO legislation and ECCTA, and effective risk management and compliance strategies in the current landscape.

