How will I know when a suspicious transaction is taking place?
Your suspicions might be aroused for any number of reasons. Often it is experience gained in your role at work and knowledge of how money launderers operate that will provide you with the experience to spot and know what to do. You might, for example, be prompted to suspect something if a customer seems to have forged identification, or, more usually, appears to want to make a transaction that is either out of character or is beyond their known financial means.
Who do I report a suspicious transaction to?
Your first port of call for any suspicious activity reporting should be our MLRO. S/he will then consider the information and decide if it warrants an official disclosure being made to the relevant authorities.
How do I report my suspicions?
You can report you suspicions about customer transactions to your MLRO either verbally or in written form. Our MLRO will then decide whether to forward your information onto the relevant authorities.
When must I report my suspicions?
This will either be before or after a transaction takes place. To a large extent the type of transaction requested by the customer will determine if you report before or after the transaction has taken place. If you report before a transaction takes place then you must be able to convincingly inform the customer that the type of service requested involves a short wait. If this can be done successfully, you should report to our MLRO who will then consider the information and decide if it warrants making a report to the relevant authorities to gain consent to proceed.
If you are unable to delay the transaction without tipping-off the customer to your suspicions, then you should make the transaction and then make a suspicion report to our MLRO as soon as possible afterwards. Our MLRO will then consider the information and decide whether an external report is required to be sent to the relevant authorities.
What happens after I have submitted a suspicion report?
If you make a report before the transaction is completed, our MLRO will consider the information and decide if an application to the relevant authorities for consent to proceed is required. They state that seven days are required for a response; during which time they will consider the report together with their own intelligence data. The response will be communicated to our MLRO and will either give consent to proceed or instruct us to refuse the transaction. If they do not respond within seven days then the MLRO is allowed to inform you to proceed with the transaction.
If you are unable to delay the customer and are forced to complete the transaction straight away, then you should submit a report immediately after completing the transaction. Once you have submitted the report, the MLRO will consider it and decide if it warrants an external disclosure, or SAR being made to the relevant authorities. If it is deemed necessary to report to them then our MLRO will use the information you provide (more detail in the report is better) to complete the SAR. It is standard that you will not get any feedback on the report, though this should not deter you from making further reports whenever necessary.
Are suspicion reports confidential?
The information exchanged in all suspicion reports (both internally and externally) are confidential with only our MLRO and the relevant authorities knowing the details.