Trends © Copyright NCA At least 1 in 4 organised crime groups retain a corrupt individual in the legitimate financial sector Illicit profits are often laundered through cash-rich overt businesses, which very often operate on the high street and typically include nail bars, food and licensed premises, companies offering security services, taxi firms and car washes. Complicit, negligent or unwitting professionals in the financial, accountancy and legal professions in the UK facilitate money laundering on behalf of organized criminals. UK organised crime groups also use specialist money launderers, some overseas, who manage laundering for multiple criminal enterprises. Government Serious Crime Review – Oct 2013

National Crime Agency (NCA) © Copyright NCA Keith Bristow Intelligence Hub

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UKFIU Structure

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Money Laundering & Legislation

Money Laundering Money laundering is commonly defined as happening in three steps: the first step involves introducing cash into the financial system by some means ("placement"); the second involves carrying out complex financial transactions to camouflage the illegal source ("layering"); and the final step entails acquiring wealth generated from the transactions of the illicit funds ("integration").

Money Laundering – What matters Raise Move Store Use What is the criminal’s objective? What is the problem they are trying to solve? What or who enables them to solve the problem? Could I be assisting? Money Laundering – Questions to ask

POCA 2002 – A Reminder © Copyright NCA s.340(9) Criminal Property Any benefit derived from criminal conduct. s.340(2) Criminal Conduct s.327 Concealing, disguising, converting, or transferring criminal property s.328 Being concerned in an arrangement in relation to criminal property s.329 Acquisition, use or possession of criminal property s.330 Failure to disclose – applies to the regulated sector s.333 Tipping off

Proceeds of Crime Act Conceal Transfer Use Possess Acquires Disguise Convert Not Protectively Marked Terrorism Act Conceal Transfer Use Possess Raise funds Remove

Consent Review – Financial Services Sector

SAR Best Practice © Copyright NCA  Put in all KYC / CDD information  Address & date of birth vital if known  Make sure your reason for suspicion is clear  Reason for suspicion should be in first line of text  Glossary code should be used  Always put postcode in even if previously reported on  If you need Consent be specific (and tick the box)  Submit via SAR Online / Fax  Be available during the notice period  Consider business / reputational risk

Consent Review Q © Copyright NCA 2,694 consent cases processed 322 (12%) problematic – represents around 500 follow-up calls 5% closed as ‘Not a Consent Matter’ 26.7% of cases there was difficulty contacting the source (MLRO) On 24 occasions Consent was closed as the reporter was unavailable for the entire notice period

Consent – Essential Elements © Copyright NCA The information or other matter which gives the grounds for knowledge, suspicion or belief A description of the property that is known, suspected or believed to be criminal or terrorist property A description of the prohibited act for which consent is sought The identity of the person or persons known or suspected to be involved in money laundering or committing or attempting to commit an offence under s15 to 18 of TACT The whereabouts of the property that is known or suspected to be criminal or terrorist property

Threat Areas © Copyright NCA Targeting by OCGs – value knowledge / access Identity fraud / false documentation to evade KYC / CDD procedures Complicit / bogus professionals High cash turnover businesses / unusually profitable Increased OCG use of offshore accounts & Company Service Providers Overseas links / international cash flow Protect Yourselves – Be Suspicious

Contact Details © Copyright NCA SAR Online & Glossary of Terms – UKFIU Support desks – UKFIU Dialogue Team via SAR Confidentiality Breach Line – NCA General Enquiries Number – Fraud Reporting