Dunnell Accounting is required under the Money Laundering Regulations 2017 to ensure we use appropriate systems and controls to prevent and prohibit any form of money laundering. In this policy we will explain and detail the procedures we have developed and continue to regularly follow in order to comply with the above regulation.

 

The current law states that as a firm, we have to actively monitor and observe each and every client of ours with the intention of ensuring they do not get involved or carry out any illegal behaviour in regard to money laundering and counter-terrorist financing through their company. Money laundering is legally classified as engaging in acts that disguise or conceal the origin of proceeds made and creating an illegitimate source of income. The Money Laundering Regulations 2017 require that we have a Nominated Officer to report to when we have suspicions of money laundering taking place within a company/organisation we provide services to.

 

The Nominated Anti-Money Laundering Officer for Dunnell Accounting is Melanie Hall, and our Anti-Money Laundering support supervisor is Devota Muikira.

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Melanie is responsible for;

• Receiving suspicion reports from support staff

• Evaluating and assessing all reports made

• Reporting any suspicions to The National Crime Agency

Devota is responsible for;

• Record keeping and monitoring documents from clients

• Carrying out risk assessment for each client

• Apply anti-money laundering procedures when onboarding

• Checking and regularly updating client documents

 

Money laundering stages: 

Placement: This involves splitting large sums of money into smaller amounts then depositing in numerous locations. This then places criminal property into the financial system and is generally the most common way to launder money.

Layering: Once money has been placed into the financial system via placement, criminals will then go through the long process of moving the money around in order to make it difficult to identify the moneys original origin. This can be done by complex transactions often involving multiple unknown companies.

Integration: After the moneys origin has been disguised and hidden, it eventually needs to reappear in the financial system, trying to prove they are legitimate funds. This would involve investing the money into other businesses such a property purchases or trusts and therefore making legitimate proceeds.

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When do we begin to report a suspicion:

As Devota is the one dealing with the client’s documents and money laundering information, she is the one responsible for reporting to Dunnell Accountings Nominated Anti-Money Laundering Officer, Melanie. Once reported, we are then unable to conduct the services we provide to the client unless our Nominated Officer says otherwise and gives us consent to continue dealing with the client. Melanie will then assess and review the suspicion we have, but if required and consented to, the suspicion will be formally reported to the National Crime Agency.

 

Money Laundering Offences

Under the Crime Act 2002, there are three main money laundering offences; The principal offences, Failure to disclose offences and the offences of tipping-off and prejudicing an investigation.

 

The Principal Offences:

Concealing – This includes concealing, disguising, converting, transferring or removing criminal proceeds from the UK

Acquisition – Use or have possession of the criminal property

 

Failure to disclose offence:

If, for example, you were found guilty of money laundering, our defence could be the report made to The National Crime Agency. However, if we never reported our suspicion or your criminal activities, we could be found guilty of failure to disclose offence and receive five years imprisonment or fines.

The offences of tipping-off and prejudicing an investigation:

Committing the tipping-off offence means we have disclosed information to the client that we have made reports to our Nominated officer or the National Crime Agency. Even informing the client about an on-going investigation conducted after our report could result in us being found guilty of this offence.

 

Within the Money Laundering Regulations 2017, there are detailed requirements and processes we comply with in order to forestall money laundering from taking place. They implement standards and procedures we have to follow when onboarding a client and conducting regular document checks and reviews. These processes set out by the regulations are client due diligence, identifying source of funds, risk assessments and training.

 

Client Due Diligent

Client due diligent refers to validating and verifying a client’s identity, obtaining their personal details for the purpose of providing them with our services and carrying out ongoing monitoring of their business’s activities.

 

Client due diligent must be carried out before we are able to establish a business relationship with a client and onboard them in our company, if a client has been inconsistent with us previously in addition to if we suspect money laundering is taking place.

 

However, if we are unable to apply client due diligence to a potential or current client of ours, we are not allowed to conduct any transactions or services for the individual, must not establish a business relationship or terminate it in addition to not accepting any funds from the client.

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Identifying source of funds

As we deal with businesses, sole traders and self-employed individuals, it is important for us to understand and identify our client’s origin and source of funds. This is a fundamental step to comply with the Anti-Money Laundering Regulations and we are required to take additional measures to identify whether our client’s transactions are consistent with their history and our knowledge of them. For example, we must not interrogate with all of their financial information or history but instead keep monitoring their financial transactions in order to assess and work out if their transactions comply with their lifestyle and behaviour.

 

Simply asking our clients where their money comes from is not enough, we must focus on understanding and evaluating how the client funds their lifestyle, whether their bank statements are consistent along with monitoring whether there are any potential signs of corruption on their behalf. If we do have any concerns or suspicions about a source of funding, we are required to report it to our Nominated Anti-Money Laundering Officer.

 

Risk assessments

Risk assessment is essential to be conducted every client of ours however it is especially important for certain clients that we do not ever meet face-to-face. Clients who may never seem to be available or request to meet us can pose a bigger risk of money laundering as we are never sure of who we may be dealing with and whether they are being authentic with us unfortunately. This requires us to take additional steps to identify their behaviour and lifestyle such as examining transactions from their accounts, staying alert for any unusual activities, keep all documents and information for a longer period.

 

Training

As Dunnell Accounting is a small business, we ensure each and every staff member is aware of the risks and dangers of money laundering. Devota has completed her Anti-money laundering test as she is our accountants support staff member and deals with the majority of client’s files and documents. All new joiners to our company will also receive relevant training in regard to money laundering to ensure of business is operating sufficiently and following all regulations required.
 

This Anti-Money Laundering Policy has been reviewed by: 

Melanie Hall 

Director of Dunnell Accounting

19/03/2020  

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