Money laundering whistleblowing policy template


The Money Laundering Regulations 2017, which transpose the Fourth EU Money Laundering Directive into UK law, came into full force on 26 June. The Fourth Directive includes some fundamental changes to the anti-money laundering procedures, including changes to customer due diligence, a central register for beneficial owners and a focus on risk assessments. For example, there will no longer be automatic exemptions from conducting client due diligence.

Further, the UK parliament has enacted a piece of sanctions and money laundering legislation designed to Brexit-proof the UK’s ability to implement international and European sanctions. The Sanctions & Anti-Money Laundering Act 2018 gives the UK new powers regarding sanctions and money laundering. For example, the UK can make, suspend and revoke sanctions regimes which can include broad measures including shipping, trade and even airspace restrictions, in addition to financial sanctions and travel bans.

What should be included in a money laundering whistleblowing policy?

A whistleblowing policy should give clear guidance and your organisation’s procedures for reporting suspicious activity. Whistleblowers should feel comfortable to raise concerns without fearing abuse from their colleagues and the policy should stress that concerns can be raised in full confidentiality. Any person who victimises a bona fide whistleblower must be liable to disciplinary action. Further, the money laundering whistleblowing policy should only be referred to with regards to concerns about money laundering, rather than to bring up personal grievances an individual might have with their organisation or a colleague.

Source: VinciWorks