Something about your client doesn’t sit right.
The money going through the business doesn’t seem to match the set-up. The company structure seems a little hard to fathom – some of the shareholders are companies based overseas.
Your instinct is that something is wrong.
In that case, it’s your duty to submit a Suspicious Activity Report (SAR).
Complete your AML survey
If you are an AAT licensed member who is supervised by AAT for AML, your firm must respond to our AML survey by Friday 6 December. Click below to find out more:
Preparing a SAR
SARs can be submitted to the National Crime Agency online. You will be required to fill out several fields – include as much information as possible, including all customer due diligence information.
All fields must be filled in – if you don’t know something, write the word “unknown”.
Make sure you include the client’s date of birth, as it’s essential to ensure they are identified correctly.
Ensure the report is clear and concise, with a summary of your suspicions, a chronological sequence of events, and no jargon or acronyms.
Explain your work briefly if you’ve been providing quite technical services. Include evidence, including financial data.
To avoid tipping off your client, you may have to undertake activities that you suspect may be offences under the Proceeds of Crime Act. In this case, you need to request a Defence Against Money-Laundering (DAML), which you can use as a defence to a money-laundering offence if necessary.
The NCA will then assess the case and inform you if you’ve been successful.
The SAR is submitted
Once you have sent in your SAR, it will be reviewed by the authorities. Again, keep your suspicions to yourself. It’s important that you do not tip the client off in any way. Ask them questions in a neutral way, as if you’re just checking your facts.
Your SAR will be investigated to determine whether a case can be built.
The National Economic Crime Centre (NECC) has strong links with the NCA, the Serious Fraud Office (SFO), the FCA, HMRC, The Home Office, The Crown Prosecution Service and City of London Police.
Within the NECC is the Joint Money Laundering Intelligence Taskforce, which is a public/private information sharing initiative to help build a better picture of the patterns within high-end money laundering. Your information may be shared there.
The investigation process
The NCA and Police will look into your SAR to determine whether there is a case to bring to court. This may involve surveillance, warrants to search properties, or a forensic investigation involving the assistance of forensic accountants.
Read more on AML as part of our #AATPowerUp Anti Money Laundering campaign for November:
- Drug dealing, money laundering and crime – just another day in the office?
- Know your anti-money laundering responsibilities inside out
- Can AI help accountants fight financial crime?
AML compliance tool
AAT licensed members can have a free 14-day trial of AMLCC – a comprehensive tool for AML compliance and risk management. There’s an exclusive discount when you register.
David Nunn is Content Manager at AAT.