AML lawyer [SRA] money laundering risks - vendor fraud through to human trafficking and modern slavery
23/04/2021
A report by the Solicitors Regulation Authority (SRA) for its most recent board meeting has highlighted an increase in the number of Suspicious Activity Reports (SARs) filed by its members about potential money laundering.
As a result of SRA work, over the past year they reported 26 money laundering related SARs to the National Crime Agency involving more than £200 million in suspected criminal proceeds. The key themes of money laundering related activity have remained broadly unchanged since last year. These include money laundering linked to:
- Residential property conveyancing
- Fraud
- Tax evasion
- Bogus investment schemes
- Clients/funds from high-risk jurisdictions
- High-risk commodities (precious and scrap metals)
- Aborted property transactions
- Vo underlying legal service or purpose for the transaction
- Complex offshore company structures/trusts
- Human trafficking and modern slavery.
Money laundering linked to vendor fraud was identified as a critical theme in the SARs we reported.
- This is where homes are targeted by fraudsters and sold without the knowledge or consent of the true owners, with the elderly and vulnerable often the victims.
The report says these SARs, which cover the 12 months to October 2020, include some £200 million in suspected criminal proceeds reported by the SRA to the National Crime Agency to support law enforcement efforts to disrupt and prosecute offenders, protect the public and tackle financial crime.
HEIGHTENED AWARENESS
But Gwilliam says the increase in SARs issued by her organisation are not down to an increase in criminal behaviour, but instead heightened awareness among solicitors about their money laundering responsibilities, and therefore greater alertness.
- "We remain committed to ensuring that all SRA staff members are aware of money laundering and terrorist financing related risks and the obligations placed upon everyone to internally report their suspicions," she says.
- "We continue to deliver a range of money laundering and terrorist financing training courses."
Read the report in full.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.