Anti-Money Laundering
The Anti-Money Laundering Policy introduces procedures to help to identify and report on instances where money laundering is suspected.
It complements the Council’s existing Corporate Fraud Policy, Whistle Blowing Policy, Anti-Bribery Policy and Financial Directives and contributes to the existing corporate governance framework to aid in ensuring that the Council is managed effectively and fulfils its statutory and regulatory duties.
The risk of exposure to money laundering activities within local government is not regarded as high. Similarly the risks to the Council of contravening money laundering legislation are low with some aspects of the legal and regulatory requirements being inapplicable to public authorities, given that the Council is not considered as a "relevant person" under the 2007 Money Laundering Regulations. Relevant persons include: credit and financial institutions; auditors; accountants; tax advisers and insolvency practitioners; independent legal professionals; trust or company service providers; estate agents; high value dealers and casinos. Nevertheless CIPFA has recommended that councils as "responsible public bodies, should employ policies and procedures which reflect the essence of the UK's anti-terrorist financing, and anti-money laundering regimes". Additionally, "CIPFA considers that there is a substantial reputational risk for an authority which does not have such policies and procedures in place". For these reasons the Council has introduced the Anti-Money Laundering Policy and requires that it is complied with.
Money laundering legislation requires all individuals within the Council to report any knowledge or suspicions that they might have of money laundering. Concerns relating to Money Laundering should be reported immediately by completing the Report to Money Laundering Officer form. The completed form should then be emailed to fraud@eastdunbarton.gov.uk.
Important - Do not `tip off' the person you are concerned is acting illegally. Tipping off is where someone informs the person who has approached the Council that they are suspected of being involved in money laundering, in such a way as to prejudice any investigation.
If any employee requires any further information or guidance relating to Money Laundering please contact the Corporate Fraud Team either by emailing fraud@eastdunbarton.gov.uk or telephoning 0141 578 8220 or 8361.