Anti Money Laundering Policy 2021 to 2022

5.1 Where you know or suspect that money laundering activity is taking or has taken place, or you are concerned that your involvement in the matter may amount to a prohibited act under the legislation, you must disclose to the Money Laundering Reporting Officer (MLRO) this suspicion or concern as soon as practicable. The disclosure should be made within hours rather than days or weeks of the information coming to your attention. The legislation determines that a single cash transaction or a series of linked transactions totalling over €15,000 (approximately £13,000 at the time of the legislation) should be treated as suspicious. However, vigilance also needs to be maintained in respect of all other possibilities such as a series of smaller payments in cash.

5.2 Your disclosure should be made to the MLRO on a Pro-Forma. The report must include as much detail as possible, for example:

• full details of the people involved (including yourself if relevant) for example name, date of birth, address, company names, directorships, phone numbers etc
  
• if you are concerned that your involvement in the transaction would amount to a prohibited act under sections 327-329 of the 2002 Proceeds of Crime Act then your report must include all relevant details
  
• you will need consent from the National Crime Agency (NCA) or relevant successor body, through the MLRO, to take any further part in the transaction. This is the case even if the client gives instructions for the matter to proceed before such consent is given. You should therefore make it clear in the report if such consent is required and clarify whether there are any deadlines for giving such consent for example a completion date or court deadline
  
• the types of money laundering activity involved. If possible cite the section number(s) under which the report is being made
  
• the date of such activities, including whether the transactions have happened, are ongoing or are imminent
  
• where they took place
  
• how they were undertaken
  
• the (likely) amount of money or assets involved
  
• why, exactly, you are suspicious
  
• in addition, any other information to enable the MLRO to make a sound judgment as to whether there are reasonable grounds for knowledge or suspicion of money laundering
  
• to prepare a report to the NCA, where appropriate. You should also enclose any copies of relevant supporting documentation.

5.3 As soon as you have reported the matter to the MLRO you must follow any directions they give to you. You must not make any further enquiries into the matter yourself.

Any necessary investigation will be undertaken by the NCA or relevant successor body as appropriate. All members of staff will be required to co-operate with the MLRO and the authorities during any subsequent money laundering investigation.

5.4 Similarly, at no time and under no circumstances should you voice any suspicions to the person or organisation you suspect of money laundering, otherwise you may commit the criminal offence of “tipping off”.

5.5 Do not, therefore, make any reference on a client file to a report having been made to the MLRO. Should the client exercise his or her right to see the file then such a note would obviously tip them off to the report having been made. Again you would be at risk of prosecution for tipping off. The MLRO will keep the appropriate records in a confidential manner.