If something doesn’t feel right about a transaction or client, then you need to act. Depending on what the risk is will determine you first steps.
If you believe that you need to report crime or matters relating to immediate risk to others, then you should be calling the police on 999 or to report a fraud, contact Action Fraud 0300 123 2040.
If it your client is being evasive or contradictory, or the transaction is unusual in size, nature or frequency, then flag it up via a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
The SARs regime is there for reporting knowledge or suspicions of money laundering, or belief or suspicions relating to terrorist financing. However, you may still have to report the matter via other routes to ensure the right information gets to the right organisation. Remember that if the funds involved are not yet the proceeds of crime then it is not money laundering, but attempted fraud.
Where you do report a crime alongside a SAR it is good practice to include the crime reference and the organisation details in the SAR.
Guidance on who exactly to report to can be found on the NCA website. It will also provide you with guidance on completing SARs, the making of consent requests and Defence against Money Laundering. The SAR Online Quick Start Guide will help you understand how to submit a SAR.
The UK Financial Intelligence Unit Signpost document signals the location of the latest SAR guidance and shows some useful links to help SAR reporters to build knowledge relevant to SAR management.
Remember though that the NCA is not a crime reporting agency.
If you are concerned about money laundering within your firm, then you should make a whistleblowing report. Our Whistleblowing Policy sets out what makes a report a whistleblow, the support available and how we will help you.
People with Significant Control (PSC) discrepancy reporting service
Firms (Obliged entities) have a requirement under the Money Laundering Regulations to report to Companies House, any discrepancies between the information on the PSC register, and the information they hold.
The Companies House PSC video below explains how the new reporting system should be used.
Requirement to register an overseas entity
The Register of Overseas Entities came into force in the UK on 1 August 2022 through the new Economic Crime (Transparency and Enforcement) Act 2022. Overseas entities who want to buy, sell or transfer property or land in the UK, must register with Companies House and tell them who their registrable beneficial owners or managing officers are.
The guidance and start page for the Register of Overseas Entity service can be found here. This guidance tells you how to register an overseas entity and declare its registrable beneficial owners or managing officers.
The land registration elements of the Act will come into force on 5 September 2022. This will allow time for those currently engaged in a relevant land transaction to comply with the requirement to register with Companies House and obtain an Overseas Entity ID before making an application to the land registry. You can read more about the Register of Overseas Entities on GOV.UK.