If you know or suspect that money laundering activity is taking place, you must report it to your line manager. If, in consultation with your manager, it is agreed that there is reasonable suspicion that money laundering may be taking place, a report should be made without delay to the MLRO. If you suspect that your line manager is, or may be, implicated in the money laundering activity, you should instead report it without delay to the MLRO under these procedures, or to the College Secretary under the College’s Fraud procedures (Ordinance C2), or its Public Interest Disclosure procedures (Ordinance D18). If you do not report the matter you may be personally liable for prosecution.

Your report should provide as much details as possible, including:

• Full details of all of the parties involved (including you and any other members of staff);
• Details of the transaction and how each person is involved with it;
• The reason that you are suspicious;
• Details of the transaction including the date, type of transaction and the amount of money or type of asset involved; and
• Any other information which may assist the MLRO decide whether the matter should be reported to the National Crime Agency.

You may choose to use the following form to make a report AML Reporting Documents.

Once you have sent your report to the MLRO you must follow any instructions that they give you. You should not make any further enquiries unless you are instructed to do so and should not voice your suspicions to anyone who you suspect of money laundering or discuss the matter with colleagues. If you were to do so, you may be committing a criminal offence, the penalty for which is up to 5 years imprisonment or an unlimited fine.

Any breach of this policy is considered to be a serious matter and is likely to result in disciplinary action.