If your business is regulated by the Money Laundering Regulations you must take steps to identify any activity you suspect may be linked to money laundering or terrorist financing. If you know or suspect there is such a link you must report it to the Serious Organised Crime Agency (SOCA). If you want to proceed with a transaction that you're suspicious of you must ask SOCA for consent.
There are several different ways of reporting suspicious activity, including online. The SOCA online reporting system is the quickest and best way to submit a report and to ask for consent to proceed with a transaction.
This guide will help you decide whether you need to report a transaction or activity. It explains when and how to report it, and includes a step-by-step guide to using the online reporting system. It also explains how to ask SOCA for consent to proceed.
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Even if you don't have proof that a transaction or activity is linked to money laundering or terrorist financing, something about it may make you suspicious.
There are many different reasons why you or one of your employees might become suspicious about a transaction or activity. Often it's just because it's something unusual for your business - perhaps a customer has tried to make an exceptionally large cash payment. Maybe the customer behaved strangely, or made unusual requests that didn't seem to make sense. Perhaps the transaction they wanted to make just didn't add up commercially.
You must look carefully at all unusual transactions to see if there's anything suspicious about them.
More guidance on the main indicators that a transaction could be suspicious can be found in Appendix 6 of the following HM Revenue & Customs leaflets.
As soon as someone in your business becomes aware of a suspicious transaction or activity they must report it to the 'nominated officer'. It's the nominated officer's responsibility to decide whether they need to send a report or 'disclosure' about the incident to SOCA. They do this by making a Suspicious Activity Report.
If the nominated officer suspects money laundering or terrorist financing they must normally suspend the transaction and make a Suspicious Activity Report. But if it's not practical - or not safe - to suspend the transaction, they should make the report as soon as possible after the transaction is completed.
SOCA receives and analyses Suspicious Activity Reports, and uses them to identify the proceeds of crime. It counters money laundering and terrorism by passing on important information to law enforcement agencies so they can take action.
Your nominated officer can send a Suspicious Activity Report to SOCA:
It's quickest and easiest to do it electronically using the SOCA online system on their website.
If you prefer you can send the report to SOCA by post. You can either:
PO Box 8000,
Or you can send the completed report by fax to 0207 238 8286.
Advice on how to complete the forms and contact details if you need more help are available on the SOCA website.
There are a number of advantages to using the SOCA online system to make a Suspicious Activity Report electronically. The online system is:
When your nominated officer submits a Suspicious Activity Report they'll get an acknowledgement by email. The email will include a unique reference number. You can use the acknowledgement email and reference number if you need to show you had no involvement in money laundering or terrorist financing. You can also use the unique reference number to provide updates to reports already submitted.
You can mark your online Suspicious Activity Reports as 'shared' or 'private'. Private reports can only be viewed and edited by the person who made them. They're not available to other people in your business, even if you've nominated them to have access to the system. Shared reports can be viewed and edited by other people in your business who have access to the system.
Before you can use the system you need to register online (see the link below). It's a good idea to register as a user and activate your account before you actually need to make a Suspicious Activity Report.
When you register you should receive an on-screen message telling you your registration has been successful. You'll also get your first activation code. Keep this safely as you'll need it to activate your account. It only appears on-screen - you can't retrieve it if you close the screen without printing it out or making a note of it.
The screen you see will explain that you'll get a second activation code sent to the email address you registered. You get the two activation codes in two different ways for security reasons. They only last for seven days, so you should activate your account promptly.
To activate your account, follow the on-screen instructions. You'll be asked to create your own suitable password. Remember that your activation codes are case sensitive, so you must enter them exactly as they appeared on-screen and in your email.
You'll need to log in to the system to make a Suspicious Activity Report. Go to the online reporting form and give as much information as you can, filling in as many fields on each screen as possible. If a field is marked with an asterisk it means you must fill it in to be able to submit a report successfully.
Save each page as you complete it to be sure you don't lose any of your work. Note that the system will automatically time out after 15 minutes of inactivity.
You should include the following key information in your report:
If you can, you should also include the following additional information about the person or people involved:
If you only have very limited information, but you think you need to submit a Suspicious Activity Report, you can make a Limited Intelligence Value Report. You can do this online by completing parts 1, 2 and 5 of the online form. As long as you complete all the fields in these sections that are marked with an asterisk you'll be able to submit your report successfully.
When you've reached the end of the online reporting form and you're ready to submit it electronically you'll have the option to save it or print it (these options appear on the screen in small text).
It's recommended that you keep a record of the report by saving it on your computer and/or printing it out. You should also either save the confirmation email you get when you submit your report, or note down the unique reference number it contains.
Keep your records safe for at least five years. You must file saved or printed copies of your reports securely to keep them confidential and to avoid the possibility of tipping off the person or people involved.
When you submit a Suspicious Activity Report online you should get an acknowledgement email from SOCA within a few minutes. If you don't receive an email within 24 hours you should contact SOCA as soon as possible on Tel 0207 238 8282 and select option three (lines are open from 9.00 am to 5.00 pm, Monday to Friday except bank holidays).
If a particular transaction or activity raises suspicions of money laundering or terrorist financing, you shouldn't proceed without getting consent from SOCA. SOCA will respond within seven days of receiving your Suspicious Activity Report.
You'll need to:
It's best to use the SOCA online system to get consent to proceed because they can be dealt with more quickly than fax or post. But if you can't get access to the system for some reason you can fax your report instead on Tel 0207 238 8286. It's not advisable to post your report if you're requesting consent because of the likelihood of delays.
You can proceed with any transaction or activity as soon as you receive consent from SOCA. SOCA will prioritise your request for consent to proceed when they look into the information you've submitted. They have seven working days to get back to you with a decision.
If you don't receive a decision from SOCA within seven working days from when they received your request you can proceed with the transaction or activity if you wish. You won't be committing an offence because consent is automatically assumed in law if no decision has been received after seven working days.
If you do get a decision within seven days but SOCA doesn't give you permission to proceed, they have a further 31 calendar days to take action. If after that further 31 days you have not heard anything from SOCA you can proceed if you want to.
You won't be committing an offence.
If you need more information about seeking consent to proceed you can call the SOCA Consent Desk on Tel 0207 238 8282 (lines are open from 9.00 am to 5.00 pm, Monday to Friday except bank holidays). Choose option four.
The SOCA website includes help and guidance on submitting Suspicious Activity Reports and using the online reporting system.
SOCA also has a dedicated support team. Their Help Desk can assist with any problems you experience when you use the online reporting system. You can contact the Help Desk on Tel 0207 238 8282 (lines are open from 9.00 am to 5.00 pm, Monday to Friday except bank holidays). Choose option three.