Legal FAQs

Legal FAQs
Q Do I have a personal responsibility to prevent Money Laundering?
Q What are the offences and penalties I risk?
Q What is the tipping-off offence and how should I avoid it?
Q Where can I get further information?
 
Do I have a personal responsibility to prevent Money Laundering?
 
YES! In fact, every employee has an obligation to report any suspicions they have in relation to Money Laundering and Terrorist Financing as per the AML policy and the Proceeds of Crime and Anti-Money Laundering Act of 2009. In addition, your role in our organisation might also have obligations that are specific to your position. These can be separated out into three categories of obligations based on whether you are senior management, general staff, or an MLRO. 
 
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What are the offences and penalties I risk?

It is important for you to understand that under the Proceeds of Crime and Anti-Money Laundering Act of 2009, you are personally liable for any Money Laundering or Terrorist Financing related crimes that you might become involved in – however trivial or accidental. These range from directly assisting in the transfer of funds for the purposes of laundering (for which you could receive up to 7 years prison sentence and a substantial fine, to failing to report any suspicions of Money Laundering you might have gained through your working duties (for which you could receive up to 14 years in prison and an unlimited fine). Because the punishments are harsh you should be aware of how to avoid committing them.

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What is the Tipping-Off offence and how should I avoid it?

Tipping-Off refers to leaking information to the person under suspicion or to a third party who could disrupt or circumvent an investigation. This should be avoided by reporting your suspicions to the MLRO using the recommended reporting channels.

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Where can I get further information?

In addition to navigating your way through the Knowledge Zone or looking for specific topics through the Knowledge Zone’s search function, you can also obtain information through our comprehensive list of links to external online resources, available from Links to other Anti-Money Laundering information

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