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Gary Clokeon 24 April 2013
Transcript of Untitled Prezi
Awareness Reporting Suspicions The Law Background Proceeds of Crime Act 2002 What is it? What sort of crimes
does it involve? Why do it? How do they do it? Placement Layering Integration The point at which criminal funds actually enter the financial system The creation of layers between the point of
deposit and eventual withdrawal Transactions designed to confuse the trail The point and which laundered money
re-enters the mainstream economy Drug Dealing Prostitution Human Trafficking It is how criminals attempt to disguise the true ownership and origins of illegal funds To hide any connection to the original crime It is often used as a way
to source criminal activities
as well, or even to finance
terrorism The classic 3 stage process Offences Failure to Report if something is obviously suspicious Tipping Off-letting the customer know they are being investigated Destroying documents or records
associated with an investigation Knowingly assisting a person to launder money The Objective test It is a criminal offence to
handle criminal property
(This includes the actual
property,i.e money and
things purchased with it What to Report How to Report Something that sounds suspicious Something that doesn't fit with normal pattern of activity Large cash deposits Attempting to go into credit Changes in account behaviour Use the online referral form found on VNET You can use "Find a Form" This is goes to the
Financial Crime Team and the MLRO More on
this later As an employee you have a legal obligation to understand and help prevent Money Laundering More about Tipping off Do not make your suspicions known to the customer Don't mention Money Laundering or Fraud Don't put notes on the system referring
to Money Laundering Do not discuss your suspicions with anyone other than the Vanquis Financial Crime Team or the MLRO Personal Implications Actively laundering money = up to 14 years imprisonment Assisting someone to launder money = up to 14 years imprisonment Failing to report something suspicious = up to 5 years imprisonment Tipping the customer off that we are suspicious of them = up to 5 years imprisonment Committing any Money Laundering offences including failing to report or tipping off are also subject to disciplinary action MLRO The Money Laundering Reporting Officer Key contact for SOCA Serious Organised Crime Agency Controlled function by the FCA Referrals delegated to Financial Crime Team Retains overall responsibility for all ML matters Our MLRO is xxxxxx Training and Record Keeping Everyone is trained when they join including contractors and temps Everyone does a refresher once a year to check you still understand your obligations All records of transactions, identity verification documents and ML referrals must be kept for 5 years Summary Don't assist anyone to launder money Report anything suspicious using the online form If in doubt - report it Don't make any notes on the system or let the customer know you are suspicious of them You can always ask for help from the MLRO xxx xxx or the Financial Crime Team The Test