SolvedCH179380 | Sanctionable conduct by tax advisers: other penalty issues: double jeopardy
From HM Revenue & Customs · Compliance Handbook
A person is not liable to a penalty for sanctionable conduct where that person has been convicted of a criminal offence in respect of the same matter.
However, concealing, destroying or otherwise disposing of required documents relating to file access notices, see , which results in prosecution, will not preclude a sanctionable conduct penalty.