SARAH DEEKS provides the busy practitioner's guide to money laundering compliance
One of the biggest changes faced by high street practitioners in the last year has been the introduction of the Money Laundering Regulations SI 2003 No 3075 (MLR 2003).
Although firms providing financial services have had procedures in place to prevent their services being used for money laundering for the past ten years (since MLR 1993) the inclusion of tax offences within the definition of money laundering has caused practitioners much anxiety.
Nearly a year on there is still uncertainty about when suspicious activity reports should be sent to the National Criminal Intelligence Service (NCIS). Out of fear of facing criminal proceedings themselves some tax practices report anything remotely suspicious or 'wrong'.
At the other end of the spectrum there are firms that refuse to believe that any of their (usually longstanding)...
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