The current political situation in many middle eastern countries is likely to result in an upsurge in the laundering of corrupt or looted funds in the UK.
All accountants in practice, as well as others working within the regulated sector in the UK, will be aware of their obligations under the Money Laundering Regulations 2007 to identify Politically Exposed Persons (PEPs) and their close associates. They should be particularly aware of the risks of their laundering of corrupt funds. These will include funds moved from a jurisdiction by ousted regime leaders and other public officials.
Where people working in the regulated sector become aware of funds which they suspect are the proceeds of corruption, being held in the UK or laundered through it, they have a legal obligation to report the suspicion to the Serious Organised Crime Agency (SOCA), whether or not the individuals involved have already been identified as PEPs.
Additional points to note
- The Egyptian Government to has specifically requested the UK to freeze the assets of several former Egyptian officials.
- Switzerland and France have already taken action against Tunisian funds held in their jurisdictions. Officials from these and other francophone jurisdictions may now be seeking alternative destinations for their looted funds, such as London.
- Up to date information on the state of play in many jurisdictions in the middle east, and information on the identity of certain of their PEPs, is available from BBC news Middle East
- Individuals working in the UK but outside the regulated sector can still make a suspicion report to SOCA without breaching any obligations for professional or contractual confidentiality. Individuals or businesses are strongly advised to do so, if they may themselves be holding corrupt funds, to avoid a criminal charge of money laundering.
- Individuals based outside the UK can also report to SOCA where they know or suspect that funds are being held in the UK, or laundered through it.
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Access guidance on making reports to SOCA
More information
Members of ICAEW can also get advice and guidance by ringing our money laundering helpline, through the Information centre on +44 (0)1908 248 250.
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