A definition of suspicion and a quality, not quantity, message were at the heart of a presentation on financial crime given by the Isle of Man Constabulary.
A momentary inkling somewhere between speculation and belief is enough to catch a potential money-launderer, according to Detective Constables Barry Moore and Kevin Roper from the Financial Crime Unit (FCU).
They said the days of people trying to
open an account with a suitcase full of cash were long gone and modern-day criminals would have all the identification required.
Finance industry employees should therefore be on the lookout for more subtle clues that could identify money-launderers.
'You should check the identity documents and the people who claim to certify them, as we have seen forged bank references. You should also check if the person is really a titled professional and authenticate copied documents.
'You should submit reports as soon as possible — we would like to know as soon as you become suspicious, before the transaction has taken place or straight away afterwards.'
They added that if a suspicious transaction report (STR) was warranted, then as much relevant information as possible should be included to make the FCU's job easier.
'We need the disclosure to fully detail the suspects with the names spelt correctly, and details of who introduced the business to you. If the company is limited you should tell us where and also tell us what research you have already done on the suspect company.
'We are not experts on every type of financial transaction so you should also tell us what should be happening if it is not the normal business process.'
Mr Moore also gave some advice on tipping off, where a financial institution is aware one of its clients is being investigated and deliberately tips off the suspect.
The offence carries a maximum sentence of five years' imprisonment or a fine of £5,000, but he added that it was an unlikely event.
'You can't tip off something that doesn't exist. If you don't know about the investigation you can't possibly be guilty of the offence of tipping off.
Many relationship managers may not be happy about their clients being investigated but the buck stops with the MLRO (money-laundering reporting officer). If you think an STR should be put in, then you must do so.'
One of the most important points outlined by the FCU team was the concept of a consent letter. They said the letter, issued by the unit, gave authority to go ahead with a particular transaction, providing all the relevant information had been entered on the STR.
'A consent letter is transaction-specific and gives consent, in accordance with the law, to conduct that business, but the ongoing relationship with that client remains unaffected.
'If the transaction has already gone through you will get an acknowledgement letter, which is not retrospective consent but will allow you to avail yourself of the law if required.'
The team said it had already received more than 2,000 STRs this year. It would only be able to provide good feedback if the quality of the information disclosed was good enough.
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