Euro Pacific Bank was previously based in St Vincent & the Grenadines. When that territory entered the common reporting standard in 2017, the bank moved to Puerto Rico. The Officer of the Commissioner of Financial Institutions (OCIF) issued a cease and desist order in response to the bank’s non-compliance with its minimum capital requirements and various violations of laws and regulations administered by OCIF.

HMRC’s campaign follows a co-ordinated day of action by members of the Joint Chiefs of Global Tax Enforcement (J5) in 2020. The J5 was formed in 2018 by the tax authorities in the UK, USA, Canada, Australia and the Netherlands to combat international tax crime and money laundering. The group shares intelligence and expertise through joint operations to tackle such activity.

Known as Operation Atlantis, the 2020 day of action was the first major operational activity for the J5. Each country independently executed enforcement actions consistent with legal requirements in their countries. These actions included intelligence and information gathering, search warrants, interviews, production orders and subpoenas.

HMRC’s nudge letter campaign is due to commence in August 2022. It will focus on several hundred customers of Euro Pacific, asking them to review their tax affairs and come forward through the Worldwide Disclosure Facility to inform HMRC of any irregularities. Recipients of the letter will be encouraged to seek representation from a specialist in this area where they don’t already have one.