Anti -Money Laundering Policy June 2021

Types of risk factors which may, either alone or along with other factors suggest the possibility of money laundering activity:

General

• 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.

Property matters

• 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)
• regarding property transactions, 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.

The following table sets out the types of activities that might be suspicious and where the council may be susceptible to money laundering activities. It is not intended to be exhaustive, and just because something is not on the list, it doesn't mean that it shouldn't be reported.