The NCA newsletter, SARs in Action, has published an article by Jonathan Fisher QC. The article, entitled ‘Meeting the challenges of COVID-19’, assesses situations created by the COVID-19 crisis in which the duty to report money laundering may arise. To businesses, Jonathan advises updated risk assessments, policies and staff training to manage AML risk exposure. Such risks exacerbate existing tensions within the AML regime, including uncertainty of the level of suspicion needed to submit a Suspicious Activity Report. Compliance with the AML regime will be a matter of scrutinising the factual position in each case.
The full article can be accessed here.
For more information on Bright Line Law’s money laundering practice see here, and for further discussion of the AML issues raised by COVID-19 see a webinar delivered by Anita Clifford here.
