Introduction

The Proceeds of Crime Act 2002 (as amended), the Terrorism Act 2002 (as amended) and the Money Laundering Regulations 2007 (as amended), impose obligations on the College in respect of money laundering and associated activities. The definition of money laundering activities under the above legislation is wide and all companies and institutions, including the College, are subject to the legislation. Non-compliance with this legislation carries financial penalties and reputational consequences for both the College and its employees (including possible individual staff criminal prosecution that could result in up to 14 years imprisonment or a large fine).

Any member of staff could be potentially committing an offence if he or she suspects money laundering, becomes involved in some way, or does nothing about it. Disciplinary action under the College’s procedures may be taken against any member of staff who fails to comply with this policy.

The purpose of this policy is to ensure that the College and its staff (in addition to members of the Council when acting on College business) comply with the legislation, and are aware of their respective obligations. The policy sets out the procedures that must be followed if an employee suspects that someone may be attempting to launder money.

It is particularly important that employees who are responsible for dealing with the receipt or outlay of funds whether in the form of cash, cheque or bank transfer are familiar with this policy and that they act without delay (as explained in the policy) if they suspect that money laundering is taking place.