Anti-money laundering policy
What are the obligations on the council?
Whilst local authorities are not directly covered by the requirements of the Money Laundering Regulations 2017, guidance from finance and legal professions, including the Chartered Institute of Public Finance and Accounting (CIPFA), indicates that public service organisations should comply with the underlying spirit of the legislation and regulations and put in place appropriate and proportionate anti-money laundering safeguards and reporting arrangements.
The regulations apply to 'relevant persons' acting in the course of business carried on by them in the UK. Not all of our business is 'relevant' for the purposes of the legislation. It is mainly accountancy and financial, company and property transactions. However, the safest way to ensure compliance with the law is to apply them to all areas of work undertaken by ourselves. Therefore, all staff are required to comply with the reporting procedure set out in this policy and the anti-money laundering staff guidance.
The obligations on us are to establish and maintain appropriate and risk sensitive policies and procedures. Organisations must:
- appoint a money laundering reporting officer (MLRO) to receive disclosures from employees of money laundering activity
- implement a procedure to enable the reporting of suspicions of money laundering
- maintain client identification procedures in certain circumstances
- maintain record keeping procedures
Section Dd7 of the council's financial regulations states that all directors need to ensure that their employees are made aware of and comply with the council's money laundering guidance.