Commentary

A7.111 Practical considerations

Administration and compliance

A7.111 Practical considerations

A7.111 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

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