Protecting against money launderers

The National Crime Agency’s National Strategic Assessment 2017 states that previous figures of £36 billion to £90 billion for all money laundering impacting on the UK are a significant underestimation.

Money launderers employ a range of techniques to help legitimise the proceeds of crime, and professionals such as accountants and solicitors are at risk of being targeted for their services.

To tackle this threat, the Home Office, in partnership with the National Crime Agency, has been working with the accountancy and legal professional bodies to raise awareness of the warning signs of money laundering, and help professionals protect themselves and their firms through the Flag It Up campaign.

Money laundering is not a victimless crime

Money laundering is not only a crime itself, but an enabler of wider serious and organised crime, which includes human trafficking and terrorist financing.

If you’re suspicious, consider filing a Suspicious Activity Report with the National Crime Agency

What should you look out for?

Some of the red flags of money laundering could include:

Clients – are they overly secretive or evasive? Do they refuse to provide all the necessary information and documents? Are there inconsistencies in what they say?

Funds – is the amount and source of funds unusual? Is the client using multiple bank accounts or foreign accounts without good reason? Are the funds received from or sent to high-risk countries?

Transactions – are there discrepancies in client transactions? Is the client involved in transactions which do not correspond to their normal professional or business activities? Are the transactions unusual because of their size, nature, frequency, or manner of execution?

If you’re suspicious, Flag It Up!

If you come across any red flags, consider submitting a Suspicious Activity Report (SAR) to the National Crime Agency.  A high quality SAR can provide crucial intelligence for law enforcement and can help to prevent a wide range of serious and organised crime and terrorist activities.  Investigations are often based on multiple SARs, and report could be the missing piece of the puzzle.

Money laundering is a critical enabler of serious and organised crime, the social and economic cost of this to the UK is estimated at £24 billion a year. There are 2 million SARs in the NCA’s database, with 419,451 SARs submitted in a year.  Between October 2015 – September 2016, £33,433,271 of assets were denied to criminals as a result of DAML SARs. Your SAR can provide the missing piece of the puzzle and help tackle terrorist financing and serious and organised crime.

You can find further information on how to submit a suspicious activity report on the NCA website.  Regulatory guidance is signposted through the Accountancy Affinity Group’s supervisory pages.

The Consultative Committee of Accounting Bodies (CCAB) has published new guidance for all entities providing audit, accountancy, tax advisory, insolvency or related services such as trust and company services. The guidance has been updated for the 2017 Anti-Money Laundering Regulations and is approved by HM Treasury.  You can access this here.

Legal professionals can find further advice on the Law Society’s anti-money laundering page and the Solicitors Regulation Authority have multiple resources available which can be accessed here.

Campaign material

Download Flag It Up campaign materials and content packs here.

Access our guidance for submitting better quality Suspicious Activity Reports here.

Legal Professionals: Flag It Up

Accountants: Flag It Up