The Proceeds of Crime Act 2002 (POCA) imposes a large number of obligations on accountants – clients must be identified client risk must be monitored software and processes set up and monitored and compliance records maintained so that compliance can be proven to regulators. All of these obligations are imposed with the intention of said accountants identifying suspicious activity or persons and making the necessary suspicious activity report (SAR) which will then lead to the National Crime Agency (NCA) being able to seize funds swiftly and effectively and make arrests.
The volume of SARs made by accountants is however very low and the cost of compliance is very high leading to concerns that the legislation is not having the desired effect and needs to be made more effective and cheaper to operate.
Suspicious activity reports
The NCA publishes a breakdown of the number of SARs...
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