The previous three years have generally heralded a new approach to combating tax evasion, with a significant international focus on cross-border cooperation and extra-territorial application of tax regimes. The U.K. has been at the forefront of this international action, legislating or proposing a series of new rules and regimes in this area. A particular focus of the U.K. authorities has been to implement legislation designed to change the behavior of individual taxpayers, targeting those directly engaging in tax evasion and individuals who indirectly facilitate or enable it. A new set of rules known as the “failure to prevent the facilitation of tax evasion” rules (UKFP rules) went into effect in the U.K. in September 2017. Designed to prevent tax evasion, the UKFP rules introduce criminal liability for certain companies and partnerships in circumstances where an employee, agent or service provider facilitates the evasion of tax by other persons. In this guest series, Sidley Austin partner Will Smith analyzes the UKFP rules. The first article provides an overview of the UKFP rules. The second article furnishes an in-depth discussion of how the UKFP rules may apply to private fund managers. See also our two-part series “Steps That Alternative Investment Fund Managers Need to Take Today to Comply With the Global Trend Toward Tax Transparency”: Part One (Apr. 7, 2016); and Part Two (Apr. 14, 2016).