Anti-Money Laundering Policy

Wiltshire Council has a zero-tolerance approach to fraud, bribery and corruption and as such takes a proactive approach to the prevention, detection and reporting of money laundering and suspected money-laundering incidents. Controls are in place to ensure compliance with policies, and the council is committed to taking all necessary steps to prevent money laundering and will seek the appropriate disciplinary and / or legal action is taken against those found to have committed money laundering and recover any losses.

Although local authorities are not obliged to comply with the requirements of the Money Laundering Regulations 2017, guidance from CIPFA indicates that they should embrace the underlying spirit of the legislation and regulations.

This Policy sets out the Council's commitment to ensuring compliance with the requirements of legislation relating to money-laundering and criminal property. The Policy supports the principles in the Council's Anti-Fraud, Bribery and Corruption Policy.

All staff have a responsibility to assist in preventing money laundering and expected staff behaviours are contained within the Code of Conduct. This policy is supported and endorsed by the Corporate Leadership Team and Cabinet.

The council's expectation is that councillors and employees at all levels will lead by example to ensure the highest standards of probity and accountability are established and strictly adhered to, and that personal conduct is above reproach at all times.

This policy applies to all employees, whether permanent or temporary, and Councillors of the Council. Its aim is to enable employees and Members to respond to a concern they have in the course of their dealings for the Council. Individuals who have a concern relating to a matter outside work should contact the Police.

This policy defines the Council's approach to managing the risk of money laundering ensuring best practice is embedded across all services, projects and partnerships. Any act of money laundering is unlawful.  This holistic approach to tackling fraud, bribery and corruption is an integral part of existing governance arrangements, policies and procedures and this policy supports the approach of providing a raft of measures designed collectively to deter would be offenders.

As a living document it is envisaged that this strategy will continually evolve as the council gains a better understanding of the potential threat from money laundering, as new threats arise, and as new and existing partnerships develop.  It has been reviewed and updated in 2024 to reflect changes required to ensure all aspects of money laundering risk are captured.

The Anti-Money Laundering Policy underpins these principles in seeking to ensure sound governance. In adopting this approach and culture the policy supports the outcomes in enabling greater engagement with the community and partners, whilst protecting the public purse.  As such this document and approach is a key support for the delivery of the council's business plan 2022 - 2032.