Introduction, definition and scope
We are committed to:
- preventing ourselves and our employees being exposed to money laundering
- identifying the risks where it may occur
- complying with legal and regulatory requirements
We have a legal obligation to ensure procedures are in place to prevent services being used for money laundering or terrorist financing.
Money laundering is linked to terrorist financing. This is the process by which terrorists fund operations to perform terrorist acts. Terrorists need financial support to carry out their activities and achieve their goals.
Any business in any sector can be subject to money laundering risks. Local government is no exception.
Definition
Money laundering is the process by which the proceeds of crime are converted into assets which appear to have a legitimate origin. They can then be retained permanently or recycled into further criminal enterprises.
Money laundering often involves three steps:
- placement – 'dirty' cash is introduced into the financial system
- layering – the proceeds are moved through a series of transactions. The purpose of this is to conceal the illegal source
- integration – a legitimate explanation for the source of funds is created. Financial wealth can be retained and potentially invested or assets acquired
Money laundering may range from a single act to complex and sophisticated schemes involving multiple parties.
Scope
All employees should be vigilant for signs of money laundering.
This policy applies to all our employees. It sets out procedures to follow when there are suspicions of money laundering activity. Not all staff will need a detailed knowledge of the criminal offences covered by the legislation. However some employees will require additional guidance to ensure awareness of money laundering.
The policy is consistent with our other policies, including the counter fraud and whistleblowing policies.
Failure by a Council employee to comply with the procedures in this policy may lead to disciplinary action being taken against them.