HMRC told us it is developing a strategy to combat phoenix companies and is beginning to use new powers alongside existing approaches to identify, and bring sanctions against, individuals involved in this practice.63 The key tools it uses include: being able to attach company debts to the individuals who served as directors; referring directors to the Insolvency Service for potential disqualification; and requiring financial securities up front from new businesses that are created as the successor of an old business.64 HMRC said it is keeping track of individuals who are potentially involved in phoenix activity (as indicated by their moving from company to company) and that this includes efforts to identify and track the ‘controlling mind’, not just the named officers, of the company.65 It told us it is identifying the insolvency practitioners that phoenix companies prefer to use, and replacing them with more stringent practitioners.66