Contents

  1. Introduction to the anti-fraud, anti-bribery, anti-money laundering and anti-corruption policy
  2. Regulatory framework – scope of policy
  3. Responsibilities
  4. Anti-money laundering
  5. Expectations
  6. Reporting fraud, bribery and corruption
  7. Client identification procedure
  8. Record keeping procedures
  9. Risk assessment, management and internal control
  10. Gifts and hospitality
  11. Proactive anti-fraud initiatives
  12. Raising concerns (whistleblowing)
  13. Annex1 – Bexley’s procedural and regulatory framework
  14. Annex2 - statutory framework
  15. Annex3 - London Borough of Bexley - code of conduct
  16. Annex4 - anti-fraud, anti-bribery, anti-money laundering and anti-corruption policy

6. Reporting fraud, bribery and corruption

As a local authority we must be extremely careful and vigilant of fraud and criminal activities. The Council is expected to provide periodic training.

Employees must report any suspected cases of fraud, financial irregularity or bribery and corruption to the appropriate manager, or, if necessary, directly to the Head of Assurance. Reporting cases in this way is essential to the success of the Anti-Fraud and Corruption Strategy.

Where you know or suspect that money laundering activity is taking/has taken place or become concerned that your involvement in a matter may amount to a prohibited act under the Act, you must disclose this as soon as practicable to the MLRO. The disclosure should be within “hours” of the information coming to your attention, not weeks or months later.  

Should you not do so, then you may be liable to prosecution.

Disclosure should be made to the MLRO.  The MLRO will consider the report and any other available internal information they think relevant and undertake such other reasonable inquiries they think appropriate to ensure that all available information is considered in deciding whether a suspicious activity report to the National Crime Agency (NCA) is required.