6 key compliance steps that recruitment businesses must take

6CATSPRO recruitment compliance

14th August 2019

Are you an owner or key stakeholder in a recruitment business with international contractors operating in direct pay models or via 3rd party suppliers such as Umbrella/Payroll/Management companies?

Are you fully aware of the compliance status of every contractor you are placing and your obligations vis-à-vis HMRC’s requirements of ‘Reasonable prevention procedures’ under the Criminal Finances Act 2017 (CFA17)?

Since September 2017 it is a corporate criminal offence for a recruitment business to fail to prevent the facilitation of tax evasion related to BOTH UK and foreign income of contractors.

Even if you service only non-UK clients this does not impact on the relevance of this legislation, it still applies!

Failure to adhere to the legislation carries criminal implications and an uncapped financial fine. Failure to demonstrate reasonable procedures to prevent the facilitation of tax evasion would impact on your ability to establish a legal defence.

6CATSPRO believe there are 6 key steps for recruitment businesses to follow:

  • Realisation – recognising the need to take action;
  • Discovery – proactively assess current risk via contractor audit;
  • Awareness – understand any risks (existing or potential) through review of audit results;
  • Reaction – proactively audit suppliers and PSL/ASL partners;
  • Prevention – define supplier SLA/KPI’s and deliver dedicated staff training workshops with details from the owners of the business of the “Top Down” policies to respect;
  • Processes – create processes for all internal functions of your business to ensure appropriate due diligence and to ensure ongoing and sufficiently robust onboarding plus monitoring and control processes to support a legal defence against a CFA17 case.

6CATSPRO offer support through all of the above steps starting with a high-level audit of your contractors under strict NDA conditions to allow you as business owners to have a clear understanding of compliance status and your risk position.

We can then deliver the appropriate International Compliance training to upskill your internal Sales and Compliance functions as well as your stakeholders and build you a robust compliance monitoring process with ongoing support.

Full services and Benefits of engaging 6CATSPRO include:


  • Ad-hoc compliance consulting – advice on new territories, compliance requirements, compliance legislation, compliance issues.
  • Compliance workshops and training– general compliance, country specific, bespoke for business requirements.
  • Existing contractor compliance risk assessment audit– high level audit to understand any compliance risk with your recruitment business
  • In depth contractor compliance health checks
  • Supplier Due Diligence pack and process – supplierdue diligence document template, process for managing communication, reviewing and monitoring compliance
  • Supplier Compliance questionnaire templates – general and country specific templates
  • Development of in-house compliance process
  • Contract templates and other compliance documentation
  • Company formation services – Germany (GmbH) & Netherlands (BV)


  • Access to practical compliance advice and information, supported by 6CATS’ network of accountants and lawyers
  • Direct access to the 6CATS’ compliance team
  • Clear in-house compliance processes
  • Greater visibility of compliance within your business
  • Greater compliance control within your business
  • Robust supplier due diligence control to demonstrate awareness of CFA17
  • Compliance support provided by an established UK audited company
  • Completely impartial advice based on many years of experience, up to date market intelligence and data

For a free confidential no obligation consultation please contact Jon Clarke on 0207 374 5791 or by e-mail jon@6catsint.com

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