Reporting Suspicions of Money Laundering

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REPORTED TO THE APPROPRIATE AUTHORITIES

Today, most financial institutions globally, and many non-financial institutions, are required to identify and report transactions of a suspicious nature to the financial intelligence unit in the respective country.

For example, a bank must perform due diligence by verifying a customer's identity and monitor transactions for suspicious activity.

To do this, many financial institutions utilize the services of special software to gather information about high risk individuals and organizations.

If a suspicious transaction is identified then this should be reported immediately either to a nominated Money Laundering Reporting Officer (MLRO) within their organisation or SOCA (Serious Organised Crime Agency)

For Accountants, the most worrying aspect of the law on money laundering relates to the offence of failing to disclose.

It is relatively straightforward to identify actual “knowledge” of money laundering and therefore of the need to disclose it, but the term “suspicion” of money laundering is not defined.

The nearest there is to a definition is that suspicion is more than mere speculation but falls short of proof or knowledge.

It is a question of judgement.

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