A common misconception we encounter among well-meaning staff working in financial services is that any reporting of suspicious activity might inconvenience the client.
This means that faced with a scenario in which their client is engaging in suspicious activity, an honest employee might hesitate to report this for fear of unnecessarily inconveniencing their client.
Let’s stop right there and take a few steps back on this.
Does the law require us to be 100% certain that our suspicions are correct before we report them?
The short answer is: no. In fact, on the contrary, we waste valuable time if we need to make sure as this delays the process of investigation that will be ongoing and based on more information than we have.
We are just one small part of the larger investigation puzzle, so we need to make sure we contribute to it as quickly and effectively as possible.
Given the difficulty with which investigations are taken forward – due mostly to lack of resources in law enforcement – the last thing we want to be doing as honest and well-meaning citizens is to be standing in the way of a serious investigation.
Is the client inconvenienced by my AML compliance, e.g., when I report suspicious activity?
A short answer again: absolutely not! The client does not know anything about your suspicions and what process is ongoing in relation to that.
All client-facing activities continue as normal because the law actually prevents you from stopping any of it! You are merely required to report your suspicions, ensuring that you smoothly contribute your bit to the ongoing investigation!
It is our role to keep clearing up any misconceptions about the law’s requirements on this, to help honest staff confidently navigate their work in compliance with the requisite laws.
Please do send through any questions or comments on this.