Money laundering or terrorist financing incident—panic sheet
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

This Precedent panic sheet takes you/the nominated officer through the initial steps in responding to a report of knowledge or suspicion of money laundering within your organisation. You should have a system for staff to report any concerns relating to money laundering or terrorist financing through a suspicious activity report (SAR).

It is likely that a money laundering or terrorist financing incident will be triggered by an internal SAR received by you/the nominated officer, but one could also arise from an employee informally raising a concern or through a request for information by a third party—a superSAR—a process introduced by the Criminal Finances Act 2017 (CFA 2017).

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.

Actions

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

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