Anti money laundering policy

9.1 Upon receipt of a disclosure report, the MLRO must note the date of receipt on their section of the report and acknowledge receipt of it. They should also advise you of the timescale within which they expect to respond to you.

9.2 The MLRO will consider the report and any other available internal information they think relevant, for example:

• reviewing other transaction patterns and volumes;
• the length of any business relationship involved;
• the number of any one-off transactions and linked one-off transactions; and
• any identification evidence held.

9.3 The MLRO will undertake such other reasonable inquiries they think appropriate in order to ensure that all available information is taken into account in deciding whether a report to the NCA is required (such enquiries being made in such a way as to avoid any appearance of tipping off those involved). The MLRO may also need to discuss the report with you.

9.4 Once the MLRO has evaluated the disclosure report and any other relevant information, they must make a timely determination as to whether: • there is actual or suspected money laundering taking place; or • there are reasonable grounds to know or suspect that is the case; and • whether they need to seek consent from the NCA for a particular transaction to proceed.

9.5 Where the MLRO does so conclude, then they must disclose the matter as soon as practicable to the NCA on their standard report form and in the prescribed manner, unless they have a reasonable excuse for non-disclosure to the NCA (for example, if you are a lawyer and you wish to claim legal professional privilege for not disclosing the information).

9.6 Where the MLRO suspects money laundering but has a reasonable excuse for nondisclosure, then they must note the report accordingly; they can then immediately give their consent for any ongoing or imminent transactions to proceed.

9.7 In cases where legal professional privilege may apply, the MLRO must liaise with the Council’s Legal Department to decide whether there is a reasonable excuse for not reporting the matter to the NCA.

9.8 Where consent is required from the NCA for a transaction to proceed, then the transaction(s) in question must not be undertaken or completed until the NCA has specifically given consent, or there is deemed consent through the expiration of the relevant time limits without objection from the NCA.

9.9 Where the MLRO concludes that there are no reasonable grounds to suspect money laundering then they shall mark the report accordingly and give their consent for any ongoing or imminent transaction(s) to proceed.

9.10 All disclosure reports referred to the MLRO and reports made by them to the NCA must be retained by the MLRO in a confidential file kept for that purpose, for a minimum of five years.

9.11 The MLRO commits a criminal offence if they know or suspect, or have reasonable grounds to do so, through a disclosure being made to them, that another person is engaged in money laundering and they does not disclose this as soon as practicable to the NCA.