Flag It Up to tackle money laundering

The National Crime Agency’s National Strategic Assessment 2018 states that there is a realistic possibility that the scale of money laundering impacting the UK annually is in the hundreds of billions of pounds.

Criminals employ a range of techniques to conceal the origins of the proceeds of crime.  Unfortunately, professionals working in the accountancy, legal and property sectors are at risk of being targeted for their skills and services.

To tackle this threat, the UK Government is working with professional bodies through the Flag It Up campaign to raise awareness of the warning signs of money laundering, promote best practice in due diligence and encourage the high-quality reporting of suspicious activity.

Money laundering is not a victimless crime

Money laundering is the process by which the profits of illegal activities are disguised and made to appear legitimate. This is not only a crime itself, but also a key enabler of other serious crimes such as modern slavery, fraud, and corruption.

File a Suspicious Activity Report with the National Crime Agency

What are some of the red flags to look for?

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 suspect that money laundering may be taking place, you must submit 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 your report could be the missing piece of the puzzle.

You can find further information on how to submit a SAR on the NCA’s website.

Money laundering is a critical enabler of serious and organised crime.  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.

Further guidance

Accountancy professionals can access the Consultative Committee of Accounting Bodies (CCAB) guidance for all entities providing audit, accountancy, tax advisory, insolvency or related services such as trust and company services.

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

Property professionals can access HMRC Money Laundering Regulations 2017 guidance and registration guide for estate agency businesses.

Legal Professionals: Flag It Up

Accountants: Flag It Up