Money laundering or terrorist financing incident—panic sheet

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

  • Money laundering or terrorist financing incident—panic sheet

Money laundering or terrorist financing incident—panic sheet

1. Money laundering incident management team

You need to be able to show you’ve taken a genuinely proactive approach, so get the right people involved from the outset. The nominated officer is ultimately responsible for making any external reports, so they should be involved at the earliest stage, if this is not already the case.

What should you do?

☐ Inform the nominated officer, if this has not already been done.

☐ Consider if any further assistance is required to handle the incident. This may not be necessary.

☐ Appoint someone to lead the team—the nominated officer (if you have one) is likely to be best placed to take on this role.

2. Contain the report

Once concerns have been raised, it is important to keep this information as confidential as possible to avoid inadvertently committing one of the tipping-off offences contained in the Proceeds of Crime Act 2002 (POCA 2002) or the Terrorism Act 2000 (TA 2000).

What should you do?

☐ Nobody should disclose the details of the suspected or actual misconduct with other persons, except where this is necessary to help the investigation.

☐ Clarify who has been made aware of the report.

☐ Take any necessary steps to limit distribution of the knowledge or suspicions.

3. Preliminary assessment

Under POCA 2002, the nominated officer must make an external SAR to the National Crime Agency (NCA) if they

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