MLRO - Working for a firm not following reporting procedures

MLRO - Working for a firm not following...

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Someone I know works for a firm of accountants and is concerned that they don't have money laundering proceedures in place.

They have identified various money laundering offences in the course of their work, most of them trivial but some of them not.

What should they do to report this?

Mike

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David Winch
By David Winch
07th Jun 2006 10:00

Reporting alone is not enough!

Mike

A firm of accountants operating in the UK falls within the 'regulated sector' doing 'relevant business' for the purposes of Part 7 Proceeds of Crime Act 2002 and the Money Laundering Regulations 2003.

As such it has to do various things including: Appoint / designate a person in the firm as Money Laundering Reporting Officer; Train relevant staff concerning the requirements of Part 7 of PoCA 2002 and the MLR 2003 and how to recognise and deal with suspect transactions; Obtain identification of new clients; Retain records of the identification obtained and relevant transactions undertaken; Report to SOCA suspicions of money laundering by persons outside the firm; Obtain consent from SOCA for any money laundering undertaken by the firm itself.

There are penalties for non-compliance - see regulation 3 MLR 2003, for example.

Simply reporting suspicions alone is not enough.

Reports should be made internally to the firm's MLRO. External reports should be made (normally only by the MLRO) to SOCA. Reports can be made online via the SOCA website .

If your friend works in a firm which has not taken any steps to comply with these requirements yet (they have been in force for more than 2 years), he may also wonder what else the firm are not doing properly. Is this a firm your friend wants to stay with?

If you are an MLRO you can get confidential one-to-one email support, information and NewsAlerts from my website www.mlrosupport.co.uk.

David
[email protected]

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