AML Reporting - Important Clarification
If you work in a “regulated sector”, of which accountancy is one, and have knowledge or suspicion (or reasonable grounds for suspicion) that money laundering is occurring or has occurred, you have a statutory obligation under the Proceeds of Crime Act 2002 (“POCA”) to disclose the circumstances to the appropriate authorities.
Your firm will have an individual who undertakes the role of the firm’s Money Laundering Reporting Officer (“MLRO”). If you are an individual working in practice, the correct course of action is to make an internal report to your MLRO, who will decide whether it is appropriate to make a Suspicious Activity Report (“SAR”) to the National Crime Agency (“NCA”). Once you have made an internal report to your MLRO, you have discharged your responsibilities under POCA.
If you are the MLRO, and decide that a SAR should be made, please note that the SAR must be made to the NCA and nobody else. Details of how to do this can be found here.
Some pages on the NCA website make reference to Action Fraud, which is only for individuals and charities that come across issues of fraud. It is NOT for professional firms. MLROs should NOT make reports using the Action Fraud helpline or website. Making a report to Action Fraud does not discharge an individual’s obligations under POCA.
All Suspicious Activity Reports must be sent to the National Crime Agency.