Consultant Barrister Tessa Lorimer explains what the Abramovich–Deloitte revelations mean for every professional adviser.
The recent BBC Panorama investigation, made with the The Bureau of Investigative Journalism, makes uncomfortable reading for anyone who signs a set of accounts.
It alleges that documents were backdated so that roughly $672m (about £508m) of superyachts, private jets and property appeared to have left one of Roman Abramovich’s Cypriot companies years earlier, and that Deloitte in Cyprus signed off accounts it knew to be misleading. A second alleged scheme concerned Kravin Investments, which had almost $2bn in the bank in 2003 and was earning substantial interest. Backdated documents were reportedly created to suggest Kravin merely held the money for its BVI parent, so that no Cypriot tax would be due on that interest. One 2005 email from the corporate services provider MeritServus spoke of the need to “change the financial statements and the accounting records accordingly”.
These are allegations. Mr Abramovich denies evading tax or concealing his wealth; his lawyers say he was not involved in the day-to-day running of the companies and that Panorama has produced no evidence he knew of or directed any falsification. Deloitte Cyprus says it cannot comment on documents more than 20 years old and that it complies with the law. But the lessons for advisers do not depend on how those disputes are resolved.
Backdating is not tax planning. It is forgery.
I spent 22 years as a government lawyer, prosecuting for the Crown Prosecution Service and the Revenue. The boundary between aggressive planning and crime is often argued over. Backdating is nowhere near that boundary.
A document that records something as happening when it did not is a false instrument. Accounts built on it are false accounts. In England and Wales that engages false accounting under section 17 of the Theft Act 1968, offences under the Forgery and Counterfeiting Act 1981 and, where several people are involved, conspiracy to defraud. Those offences reach whoever holds the pen, not only the person who benefits.
Twenty years is not a hiding place
The passage of time is the firm’s answer. For advisers, the real lesson is the opposite: leaks do not expire. The Cyprus Confidential files surfaced in 2023 and are still producing stories. Emails written in 2005 are making headlines in 2026.
Write every email on the assumption that a prosecutor, a journalist or both will read it one day.
UK law has moved on, sharply
The conduct alleged predates today’s regime, and none of what follows applies retrospectively. But if a firm with a UK connection did something similar now, it would face:
• Criminal Finances Act 2017. A firm commits an offence if someone acting for it facilitates tax evasion, in the UK or, with a UK link, overseas, unless it had reasonable prevention procedures in place.
• Economic Crime and Corporate Transparency Act 2023. A company can now be convicted of economic crimes committed by its senior managers, and since 1 September 2025 large organisations face a new offence of failing to prevent fraud.
• Enabler penalties. HMRC can impose civil penalties on those who enable offshore tax evasion.
• Sanctions. Mr Abramovich was designated by the UK in 2022. Anyone now touching assets linked to a designated person must think hard about sanctions exposure.
The direction of travel is clear. Enforcement is targeting the enablers: the accountants, lawyers, auditors and trust providers whose signatures give a scheme its air of legitimacy.
What you should do now
Firms: test your procedures against this story. Would anyone in your business flag an instruction to “change the accounts accordingly” for a prior year? If the honest answer is “maybe not”, that is your reasonable-procedures defence gone.
Individuals: if you are a partner, director or finance professional who signed off something you now worry about, take advice early, before HMRC, the SFO or a journalist calls. Early, privileged advice shapes the outcome far more than anything done after a dawn raid.
About the author
Tessa Lorimer is a Consultant Barrister at Child & Child, specialising in financial crime, contentious tax and HMRC investigations. Called to the Bar in 1990 and ranked by Chambers & Partners in Tax: Contentious: Fraud, she spent 22 years as a Senior Government Lawyer with the CPS, the Inland Revenue Solicitor’s Office and the Revenue & Customs Prosecutions Office. She is a regular commentator on Sky News, the BBC, the Financial Times and Bloomberg.
This article is for general information and does not constitute legal advice.