Anti-money laundering policy
Disclosure procedure and reporting requirements
We already have procedures in place to limit the amount of cash that we receive, with other payment methods being made available. Section Dd6 of our financial regulations stipulates that cash payments in excess of £2,000 will not be accepted.
Financial regulations Dg4 receipts, in excess of £10,000, and any bank payments from unknown or overseas banks shall be evaluated and evidenced to ensure the legitimate source of the funds.
Reporting to the money laundering reporting officer (MLRO)
Any employee who suspects money laundering activity is taking place, or an employee who becomes concerned that their involvement in a matter may amount to a prohibited act under the legislation, must disclose this promptly to the MLRO.
The disclosure should be made to the MLRO or deputy using the proforma report attached at appendix A to the anti money laundering staff guidance. The report must include as much detail as possible.
The employee must follow any subsequent directions from the MLRO or deputy and must not make any further enquiries themselves into the matter. Additionally, they must not take any further steps in the transaction without authorisation from the MLRO or deputy.
The employee must not disclose or otherwise indicate their suspicions to the person(s) suspected of money laundering. They must not discuss the matter with others or note on a file that a report has been made to the MLRO in case this results in the suspect becoming aware of the suspicion.