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Anti-money laundering

What is money laundering, and how to report it

About money laundering

The public is entitled to expect us to conduct our affairs with integrity, honesty and openness. We're not legally obliged to apply the provisions of the Money Laundering Regulations 2007. But we have taken steps to employ policies and procedures to help:

  • protect our community
  • prevent tax payers' money falling into the wrong hands

Our Anti-Money Laundering Policy outlines our commitment to creating an anti-fraud culture and maintaining high ethical standards in our administration of public funds.

What is money laundering?

Activities and offences relating to money laundering are covered by the following Acts:

  • The Proceeds of Crime Act 2002 (as amended by the Crime and Courts Act 2013, Serious Crime Act 2015 and the Criminal Finances Act 2017)
  • Terrorism Act 2000 (as amended by the Criminal Finances Act 2017)
  • Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended by the Money Laundering and Terrorist Financing (amendment) Regulations 2019) 

The primary activities and offences are:

  • concealing, disguising, converting or transferring criminal property or removing it from the UK
  • entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person
  • acquiring, using or possessing criminal property
  • failure to disclose knowledge or suspicion of another person(s) involvement in money laundering
  • tipping off or making a disclosure which is likely to prejudice an investigation being carried out by a law enforcing authority, knowing that such an investigation is in motion

Possible signs of money laundering

We're always looking out for possible signs of money laundering activity. These are risk factors, either on their own, or with other factors:

  • a new customer with no previous 'history' with the Council
  • a secretive customer: for example, one who refuses to provide requested information without a reasonable explanation
  • concerns about the honesty, integrity, identity of a customer
  • illogical third party transactions - for example, unnecessary routing or receipt of funds from third parties or through third party accounts
  • involvement of an unconnected third party without logical reason or explanation
  • payment of a substantial sum in cash (but it's reasonable to be suspicious of any cash payments particularly those over £1,000)
  • overpayments by a customer
  • absence of an obvious legitimate source of the funds
  • movement of funds to/from overseas, particularly to and from a higher risk country
  • where, without reasonable explanation, the size, nature and frequency of transactions or instructions is out of line with normal expectations
  • a transaction without obvious legitimate purpose or which appears uneconomic, inefficient or irrational
  • cancellation or reversal of an earlier transaction
  • requests for release of customer account details other than in the normal course of business
  • poor business records or internal accounting controls
  • a previous transaction for the same customer which has been, or should have been, reported to the MLRO

The following are risk factors for property transactions:

  • unusual property investment transactions with no apparent investment purpose
  • instructions to receive and pay out money where there is no linked substantive property transaction involved (surrogate banking)
  • funds received for deposits or prior to completion from an unexpected source or where instructions are given for settlement funds to be paid to an unexpected destination

About our obligations

 Organisations conducting "relevant business" must: 

  • appoint a Money Laundering Reporting Officer ("MLRO") to receive disclosures from employees of money laundering activity (their own or anyone else's)
  • appoint a Compliance Officer with sufficient authority to ensure that appropriate due diligence arrangements are in place and operating effectively for relevant services, where there is significant exposure to the risk of money laundering
  • implement a procedure to enable the reporting of suspicions of money laundering
  • maintain client due diligence procedures in certain circumstances; and
  • maintain record keeping procedures

For more information please see our Anti-Money Laundering Policy.

We've designated the Shared Internal Audit Manager as the MLRO.

How to report suspicious activities (money laundering)

If you have any suspicions or concerns of money laundering, you can contact the MLRO or the Deputy MLRO by:

  • writing to - The MLRO, Internal Audit, Borough Council of King's Lynn & West Norfolk, Kings Court, Chapel Street, Kings Lynn, PE30 1EX
  • calling - 01553 616701
  • emailing - internalauditemail@West-Norfolk.gov.uk