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An Anti-Facilitation of Tax Evasion Policy sets out how an organization prevents its employees and associates from helping others evade taxes. In Swiss business practice, these policies align with federal tax laws and international standards like the OECD's Common Reporting Standard, helping companies demonstrate their commitment to financial transparency.

The policy typically outlines risk assessment procedures, due diligence requirements for business partnerships, and clear reporting channels for suspicious activities. It's particularly important for Swiss financial institutions, wealth managers, and multinational companies who must protect themselves from involvement in tax evasion schemes while maintaining Switzerland's reputation for financial integrity.

Implement an Anti-Facilitation of Tax Evasion Policy when your organization handles financial transactions, provides tax advice, or manages wealth for clients. This policy becomes essential for Swiss banks, trust companies, and professional services firms that need to protect themselves from inadvertently enabling tax evasion schemes.

The policy proves particularly valuable during mergers and acquisitions, when onboarding new clients, or expanding into high-risk markets. It helps satisfy FINMA requirements and demonstrates compliance with Swiss anti-money laundering regulations. Many organizations adopt it alongside their due diligence procedures to create a comprehensive risk management framework.

• Basic Compliance Policy: Core version focusing on essential tax evasion prevention measures, risk assessment procedures, and reporting mechanisms - ideal for small to medium enterprises
• Financial Services Edition: Enhanced version with detailed due diligence requirements, specific to Swiss banks and wealth management firms under FINMA oversight
• Professional Services Variant: Tailored for accounting and legal firms, emphasizing client verification and transaction monitoring
• Corporate Group Policy: Comprehensive version for multinational organizations, covering cross-border transactions and international tax compliance standards
• Digital Services Format: Adapted for fintech companies and digital payment providers, addressing online transaction risks and automated monitoring systems

• Financial Institutions: Banks, wealth managers, and insurance companies must maintain these policies to prevent tax evasion through their services
• Compliance Officers: Responsible for drafting, updating, and monitoring adherence to the policy across the organization
• Board Members: Review and approve the policy, ensuring it aligns with Swiss regulatory requirements and corporate strategy
• External Advisors: Legal counsel and tax specialists who help design robust policies that meet FINMA standards
• Employee Teams: Front-line staff, relationship managers, and operations personnel who must follow the policy's procedures daily

• Risk Assessment: Document your organization's specific tax evasion risks, including client types and transaction patterns
• Regulatory Review: Gather current FINMA guidelines, Swiss tax laws, and international standards affecting your sector
• Process Mapping: Outline existing compliance procedures and identify gaps in tax evasion prevention measures
• Stakeholder Input: Collect feedback from compliance, legal, and operations teams on practical implementation needs
• Technology Check: Evaluate your monitoring systems and reporting tools for policy enforcement capabilities
• Training Plan: Develop staff education materials to support policy implementation

• Purpose Statement: Clear declaration of commitment to preventing tax evasion facilitation under Swiss law
• Scope Definition: Detailed coverage of activities, employees, and third parties bound by the policy
• Risk Assessment Framework: Structured approach to identifying and evaluating tax evasion risks
• Due Diligence Procedures: Specific steps for client verification and transaction monitoring
• Reporting Mechanisms: Clear channels for raising concerns and suspicious activity reporting
• Training Requirements: Mandatory staff education and awareness programs
• Compliance Monitoring: Internal controls and audit procedures to ensure effectiveness

An Anti-Facilitation of Tax Evasion Policy differs significantly from a Fraud Prevention Policy in several key aspects, though both address financial compliance. While they may seem similar at first glance, their focus and application in Swiss business contexts are distinct.

• Scope of Coverage: Tax evasion policies specifically target activities that could enable tax avoidance, while fraud prevention policies cover a broader range of deceptive financial practices
• Regulatory Framework: Tax evasion policies align with Swiss tax laws and FINMA requirements, whereas fraud prevention policies respond to general criminal law and financial regulations
• Risk Assessment Focus: Tax evasion policies concentrate on client transactions and tax reporting structures, while fraud policies address internal controls and general financial misconduct
• Implementation Requirements: Tax evasion policies demand specific tax law expertise and international compliance knowledge, while fraud policies typically focus on internal operational controls