All relevant businesses must maintain internal procedures which ensure employees report suspicious activity to the Nominated Officer.
There is no set template in the Regulations for an internal report. However there are requirements for the MLRO when completing and external report to SOCA. By details as much of the information below as the transaction allows, you will aid the MLRO complete his responsibilities in a timely manner.
- Name(s) of the entities involved, if company, it’s number as well
- Your internal file reference
- Current and any previous known addresses including postcode
- Date of birth of the individual
- Telephone and mobile numbers
- E mail address(s)
- Occupation and details of employer
- NI Number
- Reason for suspicion – clear and full – Tell the story
- Who, why, what, when and how
- How the suspicion arose
- Known relationships to other clients
- Is it past or is it reoccurring offence?
Past or reoccurring offences are treated different and needs explaining in some depth to avoid committing an offence along with a client.