If your business is part of the regulated sector then you need to ensure you meet the day-to-day standards set by the FSA (Financial Services Authority). These standards exist to help prevent money laundering by raising awareness, vigilance, and setting firm protocols for employees to follow whenever money laundering is suspected.
The Process of Responding to Concerns
As well as following the rules and regulations to help prevent money laundering, and carrying out due diligence checks on potential customers, it's important that members of staff understand the procedure for reporting money laundering suspicions. The quicker problems are reported, the quicker the issue can be assessed and dealt with – this is good for all involved.
- If employees become suspicious that money laundering may be occurring, their port of call should be the organisation's nominated officer. This position means they hold responsibility for sending a report to the National Crime Agency (NCA). The nominated officer is there to assess and manage suspicions, working out what needs to be reported and what can be dealt with within the business.
- Once they have assessed the severity of the issue, the nominated officer may then decide to submit a suspicious activity report (SAR) to the NCA. It is easy enough to send the report online.
- The NCA receives the SAR, and uses it to identify the proceeds of crime. From there, they can pass the information onto the relevant authorities and police so that the appropriate action can be taken.
There are many things that could spark you or your employees to become suspicious about a transaction or activity. Usually, it's because something unusual occurs within a process – and it's better to be safe than sorry.
- Reluctance to Provide Information: If the customer is secretive and evasive, then you should take it as a red flag. It sounds obvious, but if they're reluctant to disclose any information, data or documents that you need, you should avoid going into business with them.
- Incomplete or Inconsistent Information: Accountants should be on the lookout for companies using multiple tax IDs or documents that cannot be verified.
- Irregular Money Transfers and Transactions: Money changing hands in unusual ways should always raise concerns. If there doesn't seem to be a business relationship between two parties, but there is a movement of assets between them, suspicions should be raised. Unusually high turnover from cash-based businesses are another warning sign.
- Complex Group Structures: Criminal schemes are often sophisticated. If there is a complex structure with no explanation behind it, look into it further. The complexity could be covering up the layering and integration stages of money laundering without others noticing.
- Negative Reviews: It may sound obvious but if there are negative reviews of a customer, it's probably best to stay well clear.