Source of funds: clean or consistent with risk?
In many ways, client identification and verification is secondary in anti-money laundering (AML) compliance to understanding the source of funds and the purpose of a retainer.
Page 104 of the Legal Sector AML Guidance states that ‘section 330(9A) [of POCA] protects the privilege attaching to any disclosure made to a nominated officer for the purposes of obtaining advice about whether or not a disclosure should be made.'
It is that time of year again, we are all feeling festive, thinking of relaxing at home over the Christmas period with mince pies, chocolate and turkey! But what are the criminals looking forward to?
Today, company directors need to understand that the law requires them to ensure that their company is required to police itself for good corporate governance. The days have long gone when directors could say that their singular role in life was to maximise company profits, without considering the wider implications of its actions.