Sunday 26 July 2009

Tipping Point?

One Saturday last year I was dropping the offspring off at school on what turned out to be a chilly bright English September morning. Having safely achieved the designated task I started back toward the horseless carriage when my flappy ear’s pick the following statement broadcast in clear across the rapidly emptying playground “What exactly made you report this suspicious transaction report (STR) to the authorities?”

Now I spend a good part of my life helping regulated professionals understand their personal obligations under international Anti-Money Laundering Laws and regulations, particularly Section 333a (as amended) the Proceeds of Crime Act, i.e. "tipping off" and section 342 "prejudicing an investigation".

I am also sure that I spend a fair amount of my time telling people to avoid “tipping off” suspects that they are the subject of an Suspicious Activity Report or SAR by keeping details of their activity restricted to the least number of authorised people possible. So discussing your SAR activity in a public playground does appear, at least to me, something of a high risk activity. But it did get me too thinking about what it is people take away from their AML training? Is it always the message that we think it is? Or do people just go through the motions?

One lesson you might take from today’s playground event “careless talk could cost you your reputation/childhood/life/freedom for 2 years.” [Please delete as appropriate]

Point made?

TTFN

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