Voluntary Disclosure – practical issues
The currently VD procedure was announced nearly two years ago, and is set to expire at the end of December 2016. The two sub-routes (anonymous/short) have both also been extended to the same deadline. After nearly two years, the first cases have been settled, and more in the process of being settled. So, what lessons are being learned, and what should you be aware of when entering the process? The below items are based on personal experiences, as well as those of colleagues and acquaintances in the field. The initial investigation stage can take anywhere between 1-6 months. Rejections are normally