Practical ways to handle challenging money laundering situations
Practical ways to handle challenging money laundering situations

The following Practice Compliance guidance note provides comprehensive and up to date legal information covering:

  • Practical ways to handle challenging money laundering situations

This short Practice Note sets out some examples of potentially challenging money laundering situations that can arise during the usual course of business, with suggestions for how you may wish to approach them.

Situation Suggested response
You have a money laundering situation which potentially involves civil liability on the part of the firm, eg because you cannot carry out the client's instructions. Consider whether you are required to inform your insurer. If so, consider whether you telling the insurer might constitute tipping off, eg because they want to run their own investigations and this would, in turn, alert the client.
Ensure you include the need to inform insurers in any communication with the National Crime Agency (NCA) and seek the NCA's confirmation that informing your insurers will not prejudice an investigation for tipping off purposes (this is unlikely when you are dealing with a reputable insurer).
If in doubt, seek specialist legal advice or further clarification or guidance from the NCA.
You read in a newspaper about a client for whom you acted two years ago. According to the newspaper, the client has been found guilty of a large fraud—not necessarily related to the