The Council expects individuals, organisations and suppliers with whom it comes into contact to act with integrity and honesty in their dealings. The Council also expects contractors to have in place a disciplinary policy/procedure and to carry out appropriate disciplinary action in respect of any of their employees in relation to fraud or corruption.

The Council will:

• appoint a Money Laundering Reporting Officer (“MLRO”) (or Nominated Officer (“NO”) as they are sometimes referred) to receive disclosures/reports from employees of money laundering activity (their own or anyone else’s - i.e., of a client, colleague, member of the public etc.) For the Council this is the Deputy Director Legal and Democratic Services (who is the Council’s Monitoring Officer);
• appoint a Compliance Officer with sufficient authority to ensure that appropriate due diligence arrangements are in place and operating effectively for relevant services, where there is significant exposure to the risk of money laundering;
• implement a procedure to enable the reporting of suspicions of money laundering;
• maintain client identification (customer due diligence) procedures in certain circumstances;
• obtain information on the purpose and nature of certain proposed transactions/business relationships;
• conduct ongoing monitoring of certain business relationships;
• maintain record keeping procedures and other specified procedures on a risk sensitive basis; and
• train relevant staff compulsory e-learning courses on Evolve – an online, interactive learning tool and knowledge tests to ensure learning, and tailored presentations.

The MLRO is responsible for:

• Making those staff most likely to be exposed to or suspicious of money laundering situations aware of the requirements and obligations placed on the Council, and on them as individuals, by the POCA and the Terrorism Act 2000;
• Give targeted training to those considered to be most likely to encounter money laundering;
• Make arrangements to receive and manage the concerns of staff (and contractors) about money laundering and their suspicion of it, to make internal enquiries, and to make reports, where necessary to the National Crime Agency (NCA);
• Establish internal procedures to help forestall and prevent money laundering.

Not all the Council’s business is “relevant” for the purposes of the legislation: it is mainly the accountancy and audit services carried out by Financial Services and the financial, company and property transactions undertaken by Legal Services that are caught by the Act.

Chartered Institute of Public Finance and Accountancy (CIPFA) guidance notes that public authorities are not legally obliged to apply the provisions of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 , but as responsible public bodies, the Council should employ policies and procedures which reflect the essence of the UK’s anti-money laundering regime.

In addition to ongoing monitoring, the Policy will be revised to the extent that the implications of money laundering to Local Authorities are developed via new professional guidance, legal precedent or case law.