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Overlooked customer overpayment

Any AML implications?

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Client received an overpayment of a few thousand pounds from a regular customer over a year ago. 

This was overlooked until just a few months ago, at which point the client contacted the customer and has been trying to arrange repayment since - the customer has been back and forth regarding the original invoice as there is a little confusion about whether the amount invoiced was correct. There is no dispute though.

I have no doubt at all that there has been no dishonesty - the client never had any intention to retain the monies or hide the overpayment from the customer.

Are there any AML issues?

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02nd Apr 2019 13:56

If what you say is true - NO

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to bernard michael
02nd Apr 2019 15:53

Quote:

If what you say is true - NO

I agree.

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03rd Apr 2019 10:21

Except where the law specifies strict liability, for an action to be criminal there has to be" mens rea", that is to say the intention or knowledge of wrongdoing that constitutes part of a crime, as opposed to the action or conduct of the accused.
So nothing criminal in the circumstances described, so AML does not apply

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