The following Practice Compliance precedent provides comprehensive and up to date legal information covering:
We have processes whereby staff must report any knowledge or suspicion of money laundering, mortgage fraud, bribery, corruption, terrorist financing to our [nominated officer OR MLRO] (see Reducing risk below for more on these processes). The [nominated officer OR MLRO] is then under a legal obligation in certain circumstances to report that knowledge or suspicion to the National Crime Agency (NCA) through a suspicious activity report (SAR).
NCA allocates those SARs to trained financial crime investigation officers for further investigation. Intelligence from SARs may then be shared by NCA with other law enforcement or government agencies (LEAs), which may need further information. This is a financial crime investigation.
Where additional information is required from us following a SAR, it will generally be obtained through enforcement action (usually a production order) by an LEA.
This document sets out our procedure for dealing internally with financial crime investigations and enforcement actions. It describes the people involved, the steps to be taken and the timescales we aim to meet.
Our [nominated officer OR MLRO] is responsible for co-ordinating financial crime investigations within the firm and is likely to be the LEA’s first port of call and main point of contact throughout engagement by an LEA with our firm.
Before taking steps to reduce the risk of our firm being used for
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