Trends

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At least 1 in 4 organised crime groups retain a corrupt individual in the legitimate financial sector

Illicit profits are often laundered through cash-rich overt businesses, which very often operate on the high street and typically include nail bars, food and licensed premises, companies offering security services, taxi firms and car washes.

Complicit, negligent or unwitting professionals in the financial, accountancy and legal professions in the UK facilitate money laundering on behalf of organized criminals. UK organised crime groups also use specialist money launderers, some overseas, who manage laundering for multiple criminal enterprises.

Government Serious Crime Review – Oct 2013

National Crime Agency (NCA)

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Keith Bristow

Intelligence Hub

NCA

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UKFIU Structure

Head of UKFIU

UK FIU OperationsPolicy &

Communications

International & TFT

SAR Management& Disclosure

Consent

Policy, Comms & Co-ord

Dialogue

SDET

ICIC

HMRC

SAR Submissions by Year

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2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Money Laundering &Legislation

Money Laundering

Money laundering is commonly defined as happening in three steps: the first step involves introducing cash into the financial system by some means ("placement"); the second involves carrying out complex financial transactions to camouflage the illegal source ("layering"); and the final step entails acquiring wealth generated from the transactions of the illicit funds ("integration").

Money Laundering – What matters

• Raise • Move• Store• Use

• What is the criminal’s objective?• What is the problem they are trying to solve?• What or who enables them to solve the problem?• Could I be assisting?

Money Laundering – Questions to ask

POCA 2002 – A Reminder

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s.340(9) Criminal Property Any benefit derived from

criminal conduct.

s.340(2) Criminal Conduct

s.327 Concealing, disguising, converting, or transferring criminal property

s.328 Being concerned in an arrangement in relation to criminal property

s.329 Acquisition, use or possession of criminal property

s.330 Failure to disclose – applies to the regulated sector

s.333 Tipping off

Proceeds of Crime Act• Conceal• Transfer• Use• Possess• Acquires• Disguise• Convert

Not Protectively Marked

Terrorism Act• Conceal• Transfer• Use• Possess• Raise funds• Remove

Consent Review –Financial Services Sector

SAR Best Practice

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Put in all KYC / CDD information

Address & date of birth vital if known

Make sure your reason for suspicion is clear

Reason for suspicion should be in first line of text

Glossary code should be used

Always put postcode in even if previously reported on

If you need Consent be specific (and tick the box)

Submit via SAR Online / Fax

Be available during the notice period

Consider business / reputational risk

Consent Review Q4 2012

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• 2,694 consent cases processed

• 322 (12%) problematic – represents around 500 follow-up calls

• 5% closed as ‘Not a Consent Matter’

• 26.7% of cases there was difficulty contacting the source (MLRO)

• On 24 occasions Consent was closed as the reporter was unavailable for the entire notice period

Consent – Essential Elements

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The information or other matter which gives the grounds for knowledge, suspicion or belief

A description of the property that is known, suspected or believed to be criminal or terrorist property

A description of the prohibited act for which consent is sought

The identity of the person or persons known or suspected to be involved in money laundering or committing or attempting to commit an offence under s15 to 18 of TACT

The whereabouts of the property that is known or suspected to be criminal or terrorist property

Threat Areas

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Targeting by OCGs – value knowledge / access

Identity fraud / false documentation to evade

KYC / CDD procedures

Complicit / bogus professionals

High cash turnover businesses / unusually

profitable

Increased OCG use of offshore accounts & Company

Service Providers

Overseas links / international cash flow

Protect Yourselves – Be Suspicious

Contact Details

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• SAR Online & Glossary of Terms –

www.nationalcrimeagency.gov.uk

• UKFIU Support desks – 0207 238 8282

• UKFIU Dialogue Team via ukfiusars@nca.x.gsi.gov.uk

• SAR Confidentiality Breach Line – 0800 234 6657

• NCA General Enquiries Number – 0370 496 7622

• Fraud Reporting www.actionfraud.org.uk/report_fraud