There is however a further standard that has been set by the Proceeds of Crime Act, This is an objective test for reporting suspicious activity, on which we can be assessed as individuals. It is a standard of ‘a reasonable person’, what would someone else who has my qualifications and expertise would have done in the same circumstances.
It is spotting the abnormal; therefore it is about understanding your job, your role and responsibilities. Know what is normal in your working environment and activities so you can recognise the unusual and perform your tasks to a “reasonable standard”. It is about understanding the risks you face and knowing how to effectively mitigate them.
As employees of your firm, it is your firm that is required to regulated and put systems in place for supervision. It is your firms’ policy & procedures that are being scrutinised.
We can be often asked by friends to undertake work or may be tempted to earn extra income by undertaking additional works at evenings and weekends. This is very common, for example, in the accountancy profession. Be aware that any regulated activity or advice you may undertake away from the firm could put you, in your own right, “by the way of business” in the regulated sector and also requiring supervision.
Firms have different policies regarding ‘out of hours’ activities. If in doubt on your firms’ policies please ask your MLRO.