Kaley Crossthwaite advises how best to protect your firm against the threat of money laundering...& visits from the regulator
Legitimising the proceeds of illegal activity has always been a challenge for criminal organisations. For the unwitting corporate entity, holding and processing funds of uncertain provenance can carry hefty fines and potential incarceration. But is it sufficient to cross your fingers and hope that your business is not targeted and, if you are, to hope that you don’t get caught? Unfortunately these days, that is not enough.
What’s adequate?
Today, the battle against money laundering is as much about being able to demonstrate that money can’t be laundered in your organisation as it is about showing that money isn’t being laundered. Much like the Bribery Act 2010, this means not just providing evidence that money can’t be laundered but demonstrating that the processes in place are adequate to protect against the risk of money laundering. Assessing adequacy is always a challenge and will take into consideration such things as the size of transactions you are undertaking, where they originate from, where money is going