ABSTRACT
The Regulations and the Financial Services Authority Rules lay down the need to set up an internal reporting system to the money laundering reporting officer (MLRO). It is also essential that the reporting lines from the person with the suspicion and the MLRO are as short and as direct as possible. The current legislation does not only mention pure knowledge and suspicion, both of which are difficult to prove in court, but goes on to include ‘reasonable grounds’. The type of situation which may be unusual and which in certain circumstances might give rise to reasonable grounds for suspicion varies depending on the institution concerned and their customer or transactional base. The latest statistics from Serious Organised Crime Agency show that it handles 48 per cent of consent requests within a day of submission and consent is refused in 13 per cent of cases.
