General procedures
Cash payments
We will not accept cash payments that exceed £1,000. Cash is defined as notes, coins or any currency.
Identification of new clients
It is important to 'know your customer'. Employees should be wary of situations where funds flow through the Council from sources they are not familiar with. Where we are forming a new business relationship and, or considering a significant one-off transaction with a new client, we should obtain evidence of the identity of the prospective client before proceeding.
It is good practice to have either:
- one government document that verifies the name, address and date of birth or
- a government document that verifies their full name and another supporting document which verifies name and either their date of birth or address
Where it is not possible to obtain such documents, it is necessary to consider the risks associated with the client and seek advice from the MLRO or deputy MLRO.
Possible signs of money laundering
The following signs may be possible indicators of money laundering taking place and employees should be vigilant:
- concerns about honesty, integrity or location of the client
- secretive behaviour for example refusal to provide information
- attempted payment of a substantial sum of cash
- transactions which appear uneconomic, inefficient or irrational
- illogical third party transactions – unnecessary routing of funds from third parties
- illogical involvement of an unconnected third party
- funds received from an unexpected source
- instructions for payment to an unexpected source
- significant overpayments (and subsequent request for refund)
- refunds following reversal or cancellation of an earlier transaction
- no obvious legitimate source of funds
- unusual request for client account details
- poor business records or internal controls
Staff training and awareness
Staff can undertake a general fraud awareness e-learning course. This includes money laundering. Some areas of our activities may be more vulnerable to attempts to launder money. The counter fraud team will assess the risks and provide enhanced awareness training where applicable.