Commentary

A7.111 Money laundering offences—practical considerations

Administration and compliance

A7.111 Money laundering offences—practical considerations

A7.111 Money laundering offences—practical      considerations

Knowledge or suspicion

The definition of money laundering (see A7.102) is very widely drawn, but somewhere      there has to have been a criminal offence, either committed or contemplated, by      someone before the obligation to report arises. It is not necessary to know      whether or not something is in fact criminal. The suspicion that a criminal      offence has been committed gives rise to the obligation to report. The problem      is that 'suspicion' is a somewhat vague concept and is not      defined. The general position under English law is set out in the case of      R v Da Silva where Longmore LJ stated      that

'It

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