AML and counter-terrorist financing cheat sheet—for staff
AML and counter-terrorist financing cheat sheet—for staff

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

  • AML and counter-terrorist financing cheat sheet—for staff

What is money laundering?Money laundering is the process through which the proceeds of crime and their true origin and ownership are changed so that the proceeds appear legitimate.
How does money get laundered?Typically money laundering involves three stages; placement, layering and integration.
Placement—the process of placing criminal property into the financial system. This might be done by breaking up large sums of cash into smaller amounts or by using a series of financial instruments (such as cheques or money orders), which are deposited at different locations.
Layering—the process of moving money that has been placed in the financial system in order to obscure its criminal origin. This is usually achieved through multiple complex transactions often involving complicated offshore company structures and trusts.
Integration—once the origin of the money is disguised it ultimately must reappear in the financial system as legitimate funds. This process involves investing the money in legitimate businesses and other investments such as property purchases, or setting up trusts.
We are most likely to become involved in the layering stage but potentially could be involved in any stage.
What are the principal money laundering offences?The principal money laundering offences are created by the Proceeds of Crime Act 2002 (POCA 2002).
You will commit a principal money laundering offence if you:
—conceal, disguise, convert, transfer or remove criminal property from the UK (s 327)

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