MONEY LAUNDERING
Suspicious minds David Potts asks how you can harness your suspicious mind to stamp out money laundering. David Potts Director of Operations, AIA
M
oney laundering is the process by which the profits of illegal activities are disguised and made to appear legitimate. The National Crime Agency estimates that the scale of money laundering impacting the UK annually is in the hundreds of billions of pounds. The impact of money laundering is devastating, but money laundering is not only a crime itself; money laundering is a key enabler of other serious crimes such as modern slavery, drugs trafficking, fraud, corruption and even terrorism. A high quality SAR can provide a critical intelligence resource for law enforcement and be instrumental in identifying money launderers, sex offenders, fraud victims, murder suspects, missing persons, people traffickers, fugitives and terrorist financing. It’s crucial to remember that investigations are often based on multiple SARs, and your report could be the missing piece of the puzzle. Visit www.aiaworldwide.com/anti-moneylaundering-supervision for more information on the red flags of money laundering and your obligations as an AIA member under the Money Laundering Regulations 2017.
SARs overview What is a SAR?
A SAR is a Suspicious Activity Report, a piece of information which alerts law enforcement that certain client/customer activity is in some way suspicious and might indicate money laundering or terrorist financing.
Reason for suspicion
When do I submit a SAR?
As soon as you “know” or “suspect” that a person is engaged in money laundering or dealing in criminal property, you must submit a SAR.
Do I have to submit a SAR?
If you don’t submit a SAR, you may commit an offence if you have “knowledge” or “suspicion” of money laundering activity or criminal activity or do something to assist another in dealing with it. Submitting a SAR provides a defence against committing a money laundering offence.
May I inform a client/customer that I have made a report?
You must not say anything to your client/ customer which leads to an investigation being prejudiced. Once you have submitted your SAR, you should remember your obligations not to
If you suspect that money laundering may be taking place, you are legally obligated under the Money Laundering Regulations 2017 to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).”
Submitting a SAR provides law enforcement with valuable information on potential criminality. It also protects you, your organisation and UK financial institutions from the risk of laundering the proceeds of crime. By submitting a SAR to the NCA, you will be complying with any potential obligations you have under the Proceeds of Crime Act (POCA) 2002.
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ISSUE 108 | AIAWORLDWIDE.COM
