Businesses that are regulated by the Money Laundering Regulations must appoint what's known as a 'nominated officer'. The nominated officer must be someone in the business. If you're a regulated sole trader with no employees then you must act as the nominated officer yourself.
This guide explains how to appoint a nominated officer and what their role is in your business. It also explains how to train your employees to work with your nominated officer in identifying and reporting suspicious activities.
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It's the nominated officer's role to be aware of any suspicious activity in the business that might be linked to money laundering or terrorist financing, and if necessary to report it. They are responsible for:
You might decide to make your nominated officer responsible for other tasks that need to be done to make sure your business complies with the Money Laundering Regulations. For example, you could make them responsible for:
Your nominated officer for anti-money laundering must be someone in your business or organisation. They have a very important role, so it's wise to appoint someone who:
Note that the role of nominated officer should not be held by an external consultant.
If your business is a 'Money Service Business' or a Trust or Company Service Provider then the nominated officer must also pass the 'fit and proper' test. Money Service Businesses include businesses like bureaux de change, money transmission businesses and cheque cashers.
Applying for and taking the fit and proper test is part of the registration process for these types of regulated business under the Money Laundering Regulations. You can find out more about the fit and proper test by following the link below.
If the nominated officer is absent, their responsibilities can be temporarily delegated to someone else. But this doesn't relieve the nominated officer of their overall responsibility.
It's important to make alternative arrangements in the business to cover for times when the nominated officer is away. It's recommended that you appoint an alternative officer or deputy. Make sure that all your staff are aware of the alternative arrangements and know when to use them.
If you have any employees you must make sure they're aware of the laws covering money laundering. In particular, employees who deal with customers - including receptionists and anyone who answers the telephone - should receive regular training to make sure your business complies with the regulations.
You should train employees on how to recognise suspicious transactions and what to do if they identify one. They should understand how your anti-money laundering policies and procedures affect them. It's a good idea to have your anti-money laundering policies and procedures written down and available to all your staff.
Make staff aware of the penalties for committing offences under the Money Laundering Regulations and related legislation.
Important examples of best practice in employee training include:
It's a good idea to keep a log of all the training your employees receive. Getting employees to sign and date the log can help emphasise just how important it is that they follow their training at all times. An up-to-date training log also demonstrates to HMRC that your business is giving its staff the money laundering training they need.