The MLRO for the College is Anh Duong the Head of Treasury Management, (email: a.duong@imperial.ac.uk )

When a report of money laundering is received, the MLRO will:

  • Record receipt of the report and acknowledge it;
  • Assess the information received and advise the individuals concerned when a report can be expected;
  • Consider the report, make any further necessary enquiries and decide whether a report should be made to the National Crime Agency (NCA); and
  • Consider whether consent is required from the NCA before the transaction can proceed.

The MLRO may use the form set out in Appendix 2 to this policy (or a substantially similar form) for internal record keeping.

Where the MLRO decides that the case should be reported to the NCA, it should be done in a timely manner in the prescribed manner on a standard form provided by the NCA; and if the MLRO considers that consent should be sought from the NCA before the transaction can proceed this should be expressly stated on the form.

The MLRO should refer to the NCA website for guidance on making a report: http://www.nationalcrimeagency.gov.uk/about-us/what-we-do/specialist-capabilities/ukfiu/how-to-report-sars

Record keeping requirements

A record must be kept of all customer due diligence measures that have been carried out, including customer identification documents that have been obtained. Keeping comprehensive records enables the College to show that it has complied with the Money Laundering Regulations. This is crucial if there is an investigation into a suspicious transaction.

The types of record which should be kept may include:

  • daily records of transactions;
  • receipts;
  • cheques;
  • paying-in books; and
  • customer correspondence.

 The formats that records may be kept in are:

  • originals;
  • scanned; and
  • computerised or electronic.

Records must be kept for five years beginning from:

  • the date a business relationship ends; and
  • the date a transaction is completed.

Documents for reporting to the MLRO

AML Reporting Documents

Other relevant policies

The following other relevant policies are available on the College’s website:-