AML REPORTING: THE HISTORY, PROBLEMS AND POSSIBLE REFORMS FOR THE LAW ON SUSPICION

On 20 January, Bright Line Law published an article in which Jonathan Fisher QC discusses suspicious reporting which he says is at present is hindering the AML effort.  The article says that the Proceeds of Crime Act 2002 had failed to define the threshold for reporting suspicious activity with any clarity, and that subsequent judicial comments have hindered rather than helped, and even the most recent Law Commission report on the SAR regime missed an opportunity to assist.  It is said that the problem lies in the meaning of the word ‘suspicion’.  The article examines the Law Commission report findings and says that a statutory definition to delineate the boundaries of suspicion as a matter of law would sit happily alongside statutory guidance.

https://brightlinelaw.co.uk/law-commission-suspicion/

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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