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MLR - unsure what/whether to report

MLR - unsure what/whether to report

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I have a client - about to become an ex-client, but due to unrelated issues (basically I can't stand the guy and he's a real cheapskate)

He was a director of a Limited Company which has recently (Feb) been struck off - he did bring us some records to look through and there were some very strange transactions.

It looked like the company was employing several people of Polish origin on wages which would be just enough to claim tax credits - the wages were paid by a third party and the company received a small fee for this. No actual wages were paid by the company at all.

All the employees had the director's personal address as their contact details on the payslips - however the director confirmed that none of them lived there.

The director did say that the business from which his company was receiving money was handling all the payroll for this fee.

To me this looks like benefit or tax fraud - my client did have the attitude that he was a patsy but I actually suspect he was probably fine right up until he realised the s**t would land on him.

As the company is now dissolved and we never engaged the company I am wondering what I need to report, if anything.

I suspect that the payments from the company running the payroll (of which we have no details other than it is in the range of £1k to £3k) would mean I need to report my soon-to-be ex-client but would really appreciate some hand-holding here :(

Thanks in advance

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David Winch
By David Winch
30th Mar 2016 15:58

Some thoughts

Under s330 PoCA 2002 / MLR 2007 you are obliged to report suspicions of money laundering which you have, arising from information which has come to you in the course of work in the 'regulated sector', subject to certain exceptions.

I do not think it is relevant that the company is now dissolved or that it was never a client of yours.

You say, in effect, that the payslips were showing information which was false & that you suspect these false payslips may have been used for benefit fraud.  In other words you suspect money laundering by the individuals named on the payslips.  That appears to be a reportable suspicion.

You also suspect the dissolved company and its director of receiving payment for creating payslips which they knew to be false documents intended for use in fraud.  That appears to be another reportable suspicion.

It is not clear whether you suspect the company which paid money to your not-quite-a-client of being knowingly engaged in a conspiracy to defraud from which it has obtained a financial benefit.  If you do suspect that, then that appears to be another reportable suspicion.


Thanks (3)
By Discountants
30th Mar 2016 17:01

Thanks David,

I was thinking along those lines, but was unsure if my other annoyances with the client were clouding my judgement.

Thanks again :)

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