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Anti-Money Laundering Policy

Reporting Money Laundering

4.1 Money-laundering is generally defined as the process by which the proceeds of crime, and the true ownership of those proceeds, are changed so that the proceeds appear to come from a legitimate source. Money-laundering can arise from small profits and savings from relatively minor crimes, such as regulatory breaches, minor tax evasion or benefit fraud. Because banks and financial institutions have developed procedures to alert them to potential money laundering, criminals look for other ways of placing cash within the financial system (for example, by investing in property).

4.2 Circumstances that may be susceptible to money laundering for the council include but are not limited to sale of council land/buildings, sales of council properties, receipt of cash payments, and investments.

4.3 Indicators that should raise suspicion include:

  • Where the person you are dealing with is excessively secretive or obstructive
  • Where a transaction seems unusual, such as an unusually large cash payment
  • An overpayment or duplicate payment in cash where the refund is requested by cheque
  • Where a customer pays funds to the Council but then ends the transaction for no apparent reason, or unexpectedly asks for money to be refunded or forwarded to a third party
  • Where a customer tells you that funds are coming from one source and at the last minute the source changes
  • Absence of an obvious legitimate source of funds e.g. where an individual is on a low income and is purchasing a property from the Council
  • Movement of funds overseas, particularly to a high-risk country
  • Individuals and companies that are insolvent but have funds
  • Purchase of property (e.g. a Council house) where no mortgage is involved

4.2 Council employees and members must report any concerns they may have regarding money laundering, whether it relates to dishonest behaviour by council employees, Councillors, contractors or by others. That action will be free from recrimination. Such concerns will be treated in confidence and will be properly investigated. In the first instance a member of staff should contact a senior manager within the line management structure who will then liaise with the Money Laundering Reporting Officer (MLRO).

4.2 However, if the member of staff considers the matter too serious or sensitive or inappropriate to raise within the line management structure then they should contact the MLRO direct or concerns can also be raised directly to the SWAP Internal Audit Services Counter Fraud Team through their Confidential Reporting Line:

SWAP Confidential Reporting Line
Confidential Helpline020 8142 8462
Confidential Emailconfidential@swapaudit.co.uk (opens new window)
https://www.swapaudit.co.uk/contact-us (opens new window)Report it online

4.3 All matters will be treated in confidence and an expressed wish not to reveal the identity of a complainant will be respected wherever possible. (Concerns expressed anonymously are much less powerful but will be considered by the council). Alternatively, any person with a concern may use the Council's Confidential Whistleblowing Policy or as an external contact point our external auditors, Grant Thornton UK LLP.

4.4 Councillors should normally report any concerns to the Monitoring Officer who will then liaise with the MLRO.

4.5 Where you know or suspect that money laundering activity is taking/has taken place, you must disclose this as soon as practicable to the MLRO. The disclosure should be made as soon as possible. The MLRO to make a sound judgment as to whether there are reasonable grounds for knowledge or suspicion of money laundering and to enable the MLRO to prepare a report to the National Crime Agency (NCA), where appropriate. This report will usually require some investigative activity following any allegation.

4.6 Where staff may be involved there are policies that set out the approach taken. The Council's Disciplinary Policy clearly identifies the following as gross misconduct:

Dishonesty, including theft and/or fraud, falsification of records or information, non-declaration of information.

  • Serious Data protection breaches, unauthorised disclosure of council documents or confidential information to others inside or outside the council
  • Misuse of an official position for personal gain

Only a Manager / Officer at Head of Service level or above, can dismiss an employee on the grounds of gross misconduct in accordance with HR policies and procedures.

4.7 An accusation of dishonest behaviour by a Member of the council should be referred to the Monitoring Officer for an assessment of whether this is likely to constitute a breach of the Members' Code of Conduct.

4.9 Where investigation reveals evidence of suspected criminal activity with regard to money laundering the council's S151 Officer mustrefer the matter to the National Crime Agency. Where an employee is involved, the matter should be reported to the Director of HR&OD and the Head of Paid Service.

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