The nominated officer

You should:

• Have sufficient seniority to enforce your decisions when they are challenged.
• Have the authority to make external reports to the NCA without reference to another person.
• Have the time, capacity and resources to review internal SARs and make external SARs in a timely manner.
• Consider who will cover your role in your absence. Do you need a deputy?
• Read the job specification and ensure it is relevant. If there is not one, consider creating one.

When starting in this role it is important to:

• Inform ICAEW (ie, your AML supervisor) of your appointment within 14 days.
• Make sure ICAEW has your email address. We must have a current email address so that we can contact you in line with your regulatory role. Update your details by emailing amlr@icaew.com
• Ensure your appointment has been announced to staff, alongside your contact details. Staff should know who to report suspicious activity to. This is so that they can meet their regulatory responsibilities under the Proceeds of Crime Act (PoCA).

When starting in this role it is important to read and understand your firm’s current procedures for reporting suspicious activity to the NCA and ensure:

• You are registered to file SARs using the SARs portal.
• If your firm already has access to the SARs portal, that the UKFIU have the correct contact and email address for you and that you have current passwords.
• You can access and understand your firm’s previously submitted SARs and associated documentation. Ensure external SARs were made where appropriate.
  (These are not stored on the SARs portal.)
• Both internal and external SARs are stored securely and confidentially.
• You keep copies of SARs you have submitted to the NCA.
• You have a procedure for recording the reasons for submitting; or not submitting an internally reported suspicion to the NCA.
• Written procedures are updated so that staff know that you are the new reporting officer and how to report to you.
• Read your firm’s money laundering firm-wide risk assessment. Understand the risks that have previously been identified and share information with the MLCO on new and emerging trends identified in the internal SARs submitted.
• See if your firm had a visit from ICAEW (ie, its AML supervisor) in the last few years? If so ask to see the report and consider whether matters relating to SARs reporting have been resolved effectively.

Staff:

• Introduce yourself to staff. Make yourself accessible from day one. If staff have queries they need to be comfortable approaching you.

The compliance officer:

• If there is a separate role of compliance officer meet with them to discuss and understand:
  • Their expectations of your role and what information they need from you to do their job effectively.
  • The SARs that have previously been submitted. For example, the quantity of SARs, themes and red flags.
  • How you will maintain an ongoing line of communication between you and them.

Management:

• Reporting requirements. For example, will management expect regular reporting of the number of internal/external SARs, the nature of SARs, granularity of reporting and training provided or needed. Ensure appropriate procedures are in place to implement these reporting requirements.

As a money laundering nominated officer it is your responsibility to:

• Ensure staff know what to report, to who and how. This information should be included in all induction training.
• Make sure staff know what constitutes a reportable suspicious activity.
• Have regular AML updates reminding staff of red flags and current risks.
• Make sure staff know about tipping off.
• Ensure staff know there is no demiminis.
• Make sure they feel confident to approach you with a query.
• Be visible and accessible. Attend staff meetings/management meetings.
• Regularly review the quality and effectiveness of staff training.
• Regularly review the quantity and quality of internal reports.
• Understand the business.

You should ensure that you:

• Keep internal and external SARs secure.
• Review internal reports of suspicion in a timely manner.
• Report to the NCA in a timely manner.
• Keep copies of SARs submitted to the NCA. The portal does not store submitted SARs for you. ICAEW (ie, your professional body supervisor) may want to see submitted SARs.
• If you have submitted a SAR in relation to a client, you must revisit the customer due diligence.

It is important that you and your staff undertake regular anti-money laundering training. There is a wealth of resources available to you, for example via the NCA website and through guidance issued by ICAEW.

• Access essential resources

Do you report to a board?

• If so consider what management information might be required.