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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details
Anti-Money Laundering Toolkit
A toolkit to help firms communicate to and engage employees in identifying and preventing money laundering in the UK
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details
This toolkit has been designed as an interactive document.
It can be read in full or you can click straight to relevant sections. Clicking on one of the highlighted ‘live links’ anywhere in the toolkit will take you straight to where you can find more detail on that subject.
01 Introduction and Ambition Introduction and the need for the campaign 03
How to use this toolkit 03
Money laundering - not a victimless crime 04
Insights 05
02 Messaging Accountancy and legal sectors 06
Property sectors 07
Additional red flags 08 03 Campaign Advice What makes a good communications campaign 09
How to guide: events 10
How to guide: forums, blogs and social media posts 11
How to guide: content creation 12
Example newsletter 13
Evaluation 14
Example social media posts 15
04 Templates 16
05 Assets Available assets 17
06 Signposting 21
07 Contact Details 22
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details
Introduction and Ambition
IntroductionCriminals employ a range of techniques to clean their “dirty money”. Professionals working in the accountancy, legal and property sectors are being targeted because of their expert skills and services, which can give a cloak of legitimacy to illicit cash. This means that these professionals have a crucial role to play in protecting the UK’s economy, and wider society by reporting suspicious activity via Suspicious Activity Reports (SARs).
As outlined in the Serious and Organised Crime Strategy published in November 2018, ‘Flag It Up’ is a UK Government anti-money laundering (AML) initiative delivered in partnership with the legal, accountancy and property sectors. It is a communications campaign with proven success in driving professionals’ engagement with best practice in due diligence and SARs reporting. The 2016/17 campaign demonstrated that accountants and lawyers who recognised Flag It Up were twice as likely to have submitted a SAR, compared to those professionals who did not have knowledge of the campaign and this trend continued in 2017/18.
A collective response from across sectors is required to help tackle the threat, and makes things much harder for those individuals seeking to launder dirty money. By continuing to work together, we can all help to make sure it has an even greater impact when it comes to tackling money laundering in the UK.
How to use this toolkitThis toolkit is designed to provide you with tools and resources developed by the Flag It Up campaign to effectively communicate engaging AML advice to your members or staff.
Consistently communicating these key campaign messages, including advice on protective behaviours, will help to bridge the gap between awareness and action, encouraging the high-quality reporting of suspicious activity.
This toolkit will act as a central source for all campaign assets and will be an ongoing resource for you to engage in AML communications activity.
This toolkit exists alongside the campaign’s content packs, which amalgamate recent content to share (e.g. PR articles, assets from paid media partnerships etc.). These separate content packs are produced for specific activity across sectors during a campaign year. However, the toolkit has been designed for continual use when engaging on the topic of AML, regardless of when planned campaign activity is due to take place.
Integrating the Flag It Up campaign into your ongoing comms and embedding it within your organisation will help to deliver consistency across the sector, supported by HMG.
Just as the money laundering threat is changing all the time, this toolkit will also evolve to incorporate the latest advice from the National Crime Agency (NCA) and examples of best practise from partner organisations supporting Flag It Up.
The above was found in our evaluation at the end of our 2017/18 campaign activity. Please note the figures relate to accountancy and legal professionals
58% professionals claimed they were more likely to submit a SAR if they did have suspicions as a result of Flag It Up
81% professionalsclaimed the campaign material reminded them of the importance of due diligence checks
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details Organised crime groups and corrupt elites launder the proceeds of crime through the UK to fund lavish lifestyles and
reinvest in criminality
Corruption -
Undermines democracy, creates
instability and hinders global prosperity
Fraud -
3.3 million incidents in England
& Wales (year ending June 2018)
Cyber -
43% of all UK businesses identified at least one cyber security
breach or attack in 2017
5,145 potential
victims were referred to the in 2017
There were 2,503 drug misuse deaths registered in
England and in Wales in 2017
Money Laundering - Not a Victimless Crime
Statistics sourced from the NCA’s National Strategic Assessment of Serious and organised Crime 2018 (http://www.nationalcrimeagency.gov.uk/publications/905-national-strategic-assessment-for-soc-2018/file) and the National Crime Agency Annual Report and Accounts 2017–18 (http://nationalcrimeagency.gov.uk/publications/915-nca-annual-report-account-2017-18/file)
Drugs-
Slavery and human trafficking
-
(a 35% increase on 2016)
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details
Over £5 billion a year is spent by our financial institutions complying with regulations. It is therefore essential to ensure that when sharing intelligence and reports we focus on producing quality not quantity and value is being gained from this £5 billion spent.
• 100s billions - National Crime Agency’s National Strategic Assessment 2018 (link here if needed: http://www.nationalcrimeagency.gov.uk/publications/905-national-strategic-assessment-for-soc-2018/file)• SARs – www.gov.uk, 26th October 2018, news story entitled: “Campaign to prevent properties being bought with dirty money” (link here if needed: https://www.gov.uk/government/news/government-
campaign-to-prevent-properties-bought-with-dirty-money)• Prison – ibid• 1,400 convictions - www.gov.uk, 7th December 2018, news story entitled: “UK takes top spot in fight against dirty money”• £48 mil - www.gov.uk, 1st November 2018, news story entitled: “Government launches new strategy to tackle serious and organised crime” (link here if needed: https://www.gov.uk/government/news/
government-launches-new-strategy-to-tackle-serious-and-organised-crime)• £5bil - ibid
Up to 2 years in prisonand prevention from trading and unlimited fines could be faced by professionals if failing to comply with money laundering regulations.
Only 8,406 SARs (Suspicious Activity Reports)
were submitted by accountants, lawyers and estate agents over the period April 2017 to March 2018. Nearly 60% comes from accountants, 32% from lawyers and 8% from estate agents. The NCA expects far more SARs to be filed flagging suspicious transactions.
1,400 convictions a year are achieved through aggressive investigation and adopting new tools such as Unexplained Wealth Orders.
Funding of £48 million from 2019 to 2020will be the minimum received by the government’s new Serious and Organised Crime Strategy to further ramp up law enforcement capabilities to specifically tackle illicit finance.
100s of billions Money laundering in the UK potentially runs to hundreds of billions of pounds per year according to the National Crime Agency’s National Strategic Assessment 2018.
Insights
Professionals such as lawyers, accountants and estate agents are at risk of being targeted by criminals for their services. Therefore, professionals in these sectors are an important part of the response to money laundering. Due to the prevalence of dirty money in the UK, reporting from these sectors is assessed to be low relative to the threat.
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
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Messaging
Accountancy and legal sectors:
Campaign messages
Criminals may try to exploit your services. It’s your personal responsibility to conduct thorough due diligence to protect yourself. Don’t be guilty of facilitating money laundering.
The impact of money laundering on society is devastating. Don’t help to line the pockets of criminals who commit modern slavery, human trafficking or fraud.
Money laundering has severe penalties. You could damage your firm’s reputation, lose your licence or face prosecution.
Even when the proper process is followed, things can slip through if you don’t look close enough.
Campaign red flags
• Transactions: Are transactions unusual because of their size, frequency or the manner of their execution, in relation to the client’s known business type?
• Structures: Do activities involve complex or illogical business structures that make it unclear who is conducting a transaction or purchase?
• Assets: Does it appear that a client’s assets are inconsistent with their known legitimate income?
• Resources: Are a client’s funds made up of a disproportionate amount of private funding, bearer’s cheques or cash, in relation to their socioeconomic profile?
• Choice of Professional: Have you, or other professionals involved been instructed at a distance, asked to act outside of your usual speciality, or offered an unusually high fee?
• Political Status: Is the client engaged in unusual private business given that they hold a prominent public title or function, or given their ties to an individual of this nature?
• Documents: Are information or documents being withheld by the client or their representative, or do they appear to be falsified?
• Identity: Has a client taken steps to hide their identity, or is a beneficial owner difficult to identify?
• Behaviour: Is the client unusually anxious to complete a transaction or are they unable to justify why they need completion to be undertaken quickly?
• Geographical Area: Is collateral provided, such as property, located in a high-risk country, or are the client or parties to the transaction native to or resident in a high-risk country?
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
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Signposting
Contact Details
Campaign messages
As your industry changes, don’t leave yourself open to criminal exploitation. It’s up to you to protect yourself.
Messaging
Property sector:
If something doesn’t feel right, flag it up. Better to be safe than sorry.
Criminals are using sophisticated methods to clean dirty money. Make sure that you know how to spot the red flags.
You could lose your job, your licence and face prosecution if you don’t report suspicious activity – make sure you know the proper process for reporting.
Campaign red flags
• Identity: Does the buyer or seller take steps, such as using intermediaries, to hide their identity, or is the beneficial owner difficult to identify?
• Resources: Does a buyer appear to be conducting a purchase that is beyond their financial means? Are they unwilling to disclose where funds are coming from?
• Documents: Is information or documentation withheld by the buyer, seller or their representative? Do any of their documents appear to be falsified?
• Behaviour: Does the buyer or seller seem unusually anxious to complete a transaction?
• Transactions: Are transactions unusual in their size, frequency or manner of execution, in relation to the buyer or seller’s known business type?
• Assets: Does a buyer or seller’s assets, such as their property, seem to be inconsistent with their legitimate income?
• Professional: Have you, or other professionals involved, been instructed at a distance, have you been asked to act outside of your usual speciality, or have you been offered an unusually high fee?
• Structures: Do activities involve unnecessarily complex or illogical business structures that make it unclear who is conducting a transaction or purchase?
• Political Status: Is the client engaged in unusual private business given that they hold a prominent public title or function? Or do they have ties to an individual of this nature?
• Geographical Area: Is the collateral provided for a transaction, such as property, located in a high-risk country? Are parties to the transaction native to or resident in a high-risk country?
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
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Signposting
Contact Details
Messaging
Additional red flagsThe following table contains further potential red flags that have been consolidated from those are contained in publications from the Financial Action Task Force (FATF). This includes Money Laundering and Terrorist Financing Vulnerabilities of Legal Professionals (2013), and Money Laundering and Terrorist Financing through the Real Estate Sector (2007). It has also taken into account the risk factors published in the Consultative Committee of Accountancy Bodies (CCAB) Anti-Money Laundering Guidance for the Accountancy Sector (2018), and the Legal Sector Affinity Group’s Anti-Money Laundering Guidance for the Legal Sector (2018). These documents have been approved by HMRC and HMT respectively.
Client Funds Transactions Choice of professional
Asks for complicated structures of ownership to be put in place, possibly
involving multiple countries.
Channelling funds through multiple accounts/transactions adding a layer of complexity.
Unexpected changes in payment procedures that are inappropriate for the common
practice used for the ordered transaction.
The professional has changed over a short period of time, or the service was previously refused, or a previous relationship terminated.
Is known to have convictions for acquisitive crime or terrorism, or is
associated with someone who does.
The source of funds is a cryptocurrency, without a sufficient explanation provided.
Multiple transactions occur between the same parties in a short space of time.
The use of correspondent banking services which often hold limited
due diligence information.
A company’s capital has significantly increased over a short period of time, or an increase in
capital from a foreign country without explanation.
Back to back transactions with rapidly increasing value (e.g. property sales).
The parties involved are connected, without an apparent business reason.
Large cash payments to purchase property where the source of funds is unclear – lack of co-
operation from client to evidence this information.
There is a request for payment to be broken up with little time between.
The professional asks for funds to be transferred into their own account.
Uses an intermediary or agent, or avoids contact. Structuring cash payment flows through
the use of multiple accounts to avoid monetary thresholds put in place by
overseas jurisdictions (‘cash funnelling’).
Payments in large sums of cash without sufficient explanation.
Holds or has previously held a political or high-level appointment, or has professional
or family ties to such an individual, and is engaged in unusual private business.
Mortgages repeatedly paid prior to maturation date without logical explanation, or problematic mortgages paid off in cash.
The client uses a professional / firm that is not in keeping with their services, i.e.
the scale of the transaction or location of the property suggest another professional
/ firm would be better suited to act.
The client business is unusually not visible on the internet or appears to have a very basic website that is out
of character for services offered. Structuring cash payment flows through the use of multiple accounts to avoid monetary thresholds put in place by
overseas jurisdictions (‘cash funnelling’).
Unexplained last minute change in instructions regarding transactions.
Customer or counterparty declines services or facilities that they should find
attractive without a clear justification.
Property sales at prices which are significantly above or below market price, or a transaction which appears
uneconomic or inefficient.
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details
Campaign Advice
What makes a good communications campaign?Great campaigns are based on great planning – whatever the scale. There are a few basic steps worth following in any campaign:
Set specific objectives What is the issue that you are trying to address? What do you need to do to achieve this? For example,
make x% of employees more resilient to money laundering by achieving
x% recall of the key red flags.
1Refine your target audience
Who are the most vulnerable groups within your workforce? What are their
characteristics? Are they based in certain departments or regions? What is the
most effective way to reach them?
2Tailor your messages
Adapt the messages in this toolkit to suit your organisational needs. Use an interesting ‘hook’ to engage your employees and
make the content relevant. Case studies are an effective way to bring information to life.
3
Choose your channels How do your employees receive their information? For example, are they more likely to attend a lunchtime information session or participate in a discussion group
hosted on the intranet? Then structure your campaign accordingly.
5 4Set your targets
Identify ways to track the effectiveness of your activity.
For example, more than 30 employees joining an event. Use this information
to optimise activity going forward.
6
Close the loop
Thank any supporters and share your successes on
internal channels and with senior management teams.
7
Please inform us of your successful campaigns at [email protected]. We may include them in the future versions as examples of best practice.
Evaluate your activity Did you achieve your targets? What worked well and what
could be improved? Factor in any learnings for future activity.
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Flag It Up ToolkitContents
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Free materials, which can be co-branded, are available to download to help you promote your Flag It Up event and its content.
Create a presentation to deliver at the event using templates that can be tailored to suit your organisation.
Choose a location/room that is accessible and provides high footfall. More informal set-ups and seating plans allow for greater interaction and therefore engagement.
Consider using tablets for surveys or displaying advice, the Sli.do app for live polling and incorporating video materials to make your event more interactive and hold the audience’s attention.
Build in time for Q&A so that the audience has the opportunity to contribute to the discussion and ask questions.
Don’t forget to provide contact details and useful links so people can find more information.
Try to ask feedback questions to understand areas of strength and those that need improvement.
Use Flag It Up posters and leaflets so it’s immediately clear what your event is about.
Events
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Campaign Advice
How to guide: eventsFace to face meetings and events are amongst the most powerful ways to engage with busy internal audiences. A well-run event can give you the opportunity to understand your audiences better and improve the way you communicate with different demographics or teams.
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Flag It Up ToolkitContents
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Campaign Advice
How to guide: forums, blogs and social media posts Using online internal communications channels such as intranet based discussion forums, blogs, newsletters and social media posts are an effective way are an effective and economic way of increasing the reach of your campaign across your organisation.
Map out when you will post during your campaignFlag any external events that might spark further interest in or conflict with your campaign aims and agree frequency of posts based on what’s worked well previously
Work out how you’re going to reply to commentsConsult your existing moderation policy or create one to deal with any abusive or inappropriate comments
Try to avoid ‘naked’ postsEach post should include a picture or video
Use language and a tone of voice to appeal to your target audienceBring your content to a wider audience and increase its impact
Tailor your content for the channelCertain networks are more reactive and fast paced, whereas others can accommodate longer, more reflective posts
Get to know your audience by asking open-ended questionsThis helps boost engagement in your posts
Use calendar hooks to boost engagementLink your content to things that are happening in the ‘real world’ e.g. new regulation or how criminals can slip through AML checks during the busy Christmas season
Get the right permissions for the images you usee.g. has anyone featured given consent to be photographed and for the image to be used in this way?
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Flag It Up ToolkitContents
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Campaign Advice
How to guide: content creation Effective communication is paramount to ensure your employees are engaged and understand the key messages.
1 Find your ‘hook’Provide a reason to be talking to your audience now, e.g. recent cases of money laundering in your sector
5 Keep it short and snappy Shorter pieces of 300 words or less will help keep employees engaged in a busy work environment
6 Major on the message Ensure the Flag It Up campaign messages and/or red flags appear early in any content and are quickly and clearly conveyed
7 Focus the mind
Where possible focus on one area of advice or theme e.g. does a transaction seem unusual because of its size or manner of their execution?
8 Provide proof pointsMake use of the research referenced in this toolkit or draw quantitative data from your own research to ground the piece in evidence
9 Include a call to action Encourage readers to ‘do’ something as result of the content by including links to more information or top tips to be followed at the conclusion of the article
3 Tailor the advice to your organisation Frame the guidance to the sector or type of organisation you operate. e.g. a law firm’s employees may be more aware of the SAR process but need more motivation and an estate agent may need to be run through the processt
4 Weave in employee case studiesStories and opinions from colleagues draw in readers and help to bring a story to life
2 Make use of existing assetsA wealth of content has been created for the Flag It Up campaign which can be shared with you members/staff. These are readily available via our digital channels and can be found on the Assets and Signposting tabs of this toolkit
For our PR and social media peaks, e.g. #DirtyMoney and #FlagItUp, we create bespoke toolkits for Partners containing content that can be shared with both internal and external audiences. These are available on request via [email protected]
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Flag It Up ToolkitContents
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Campaign Advice
Example newsletter Supporting the Flag It Up campaign within an internal newsletter is an effective way of providing your workforce with the key messages and red flags they need to spot money laundering threats within your organisation and communicate concerns.
Below is an example newsletter from the International Association of Bookkeepers (IAB) in support of the Flag It Up campaign launch in October 2018. You are welcome to use the below as a template for your own newsletter or as inspiration for your own specific newsletter on the topic. Selecting the messages of most relevance and importance to your staff will of course make for the most effective and engaging newsletter.
You can download and share campaign materials from FlagItUp.campaign.gov.uk. These can be utilised for internal training purposes, or to demonstrate your support for tackling money laundering on social media.
Bookkeepers urged to Flag It Up and tackle the threat from dirty moneyThe IAB is proudly supporting Flag It Up, the Government’s anti-money laundering campaign, and is encouraging you, our members, to do the same. The new look campaign was re-launched in October to urge professionals working in the accountancy sector to remain alert to the red flags of money laundering, and report any suspicious activity via a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
Money laundering is a dirty businessThe NCA states that the volume of dirty money laundered annually through the UK could be in the hundreds of billions of pounds. The impact of this is devastating. Money laundering is not only a crime in itself, but it also enables the proceeds of crimes such as corruption, fraud, modern slavery, or drugs trafficking to be enjoyed or reinvested, and contributes to ongoing criminality. These criminals are targeting our sector with increasing sophistication, and the risk of your skills being exploited is a very real threat. For professional accountants, even unintentionally facilitating money laundering is a risk which carries severe penalties, including fines and prosecution.
As bookkeepers, you are in an unrivalled position to identify any suspicious activity within client accounts, and have a professional duty and legal obligation to report anything which constitutes suspicious activity. A high quality SAR can provide crucial intelligence for law enforcement, and by flagging your suspicions, you are playing a key role in tackling dirty money, and helping to build a safer society and stronger economy
Know the signs, report the crime:
• As well as conducting a risk-based due diligence approach for both new and existing clients, harnessing your professional intuition is crucial to spotting the red flags:
• Transactions: Are transactions unusual because of their size, frequency or the manner of their execution, in relation to the client’s known business type?
• Structures: Do activities involve complex or illogical business structures that make it unclear who is conducting a transaction or purchase?
• Assets: Does it appear that a client’s assets are inconsistent with their known legitimate income?
• Resources: Are a client’s funds made up of a disproportionate amount of private funding, bearer’s cheques or cash, in relation to their socioeconomic profile?
• Documents: Are information or documents being withheld by the client or their representative, or do they appear to be falsified?
• Identity: Has a client taken steps to hide their identity, or is beneficial owner difficult to identify?
• Behaviour: Is the client unusually anxious to complete a transaction or are they unable to justify why they need completion to be undertaken quickly?
• Geographical Area: Is collateral provided, such as property, located in a high-risk country, or are the client or parties to the transaction native to or resident in a high-risk country?
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How to guide: evaluation Evaluating campaign activity of any size is vital. It allows you to report successes, learn fromwhat did or didn’t work and make sure you’re constantly improving.
Inputs
What specific activity went into the campaign
e.g. cost of leaflets
Outtakes
What did the audience think or do to make
that decision
e.g. the number of people who clicks on
your social media posts
Outputs
What was delivered
e.g. 2 events and 500 leaflets distributed
Outcomes
The impact of your activity on the ultimate objective
e.g. x% people saying they would adopt the behaviours as a result
of the activity
Split out your metrics using this model:
Build evaluation infrom the very beginning, with regular checks as the campaign progresses so you know you’re on target.
Set SMART objectives Specific, Measurable, Achievable, Realistic, Time bound – which you can measure and track. e.g. a % increase in SARs produced by [enter date] as a result of your campaign.
Use existing data If you have it, or carry out a short survey before you start activity so you have a ‘baseline’ from which you can then identify shifts in your staff’s awareness, understanding and reporting of suspicious behaviour.
Draw on quantitative (numbers and statistics) and qualitative (longer form answers) information.
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Example social media posts Below are examples of social media posts that could be used to support the campaign. Feel free to use these verbatim or as inspiration. Remember the key hashtags of #FlagItUp and #DirtyMoney
To facilitate money laundering is a criminal act and you could lose money, your job and
your licence. You could even face prosecution. #DirtyMoney, know the signs, report the
crime #FlagitUp flagitup.campaign.gov.uk
Help stamp out #DirtyMoney with Flag It Up’s red flags of money laundering
flagitup.campaign.gov.uk
Money laundering isn’t always obvious, but you could be fined or prosecuted for missing
the signs. Know the signs, report the crime and submit a SAR if you are suspicious
http://flagitup.campaign.gov.uk #FlagItUp
#Lawyers, you have a crucial role to play. Don’t close your eyes to the warning signs of #DirtyMoney, remember to #FlagItUp flagitup.campaign.gov.uk
Accountants are a crucial line of defence for tackling money laundering. That’s why you are under a legal and moral
obligation to submit a SAR. #DirtyMoney #FlagItUp flagitup.campaign.gov.uk
The property industry is changing and criminals are getting smarter. Don’t leave yourself open to exploitation. It’s your job to protect yourself from
#DirtyMoney Find out more about SARs here
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Templates
Blog template Below is an example blog which could be used to the support the campaign.
According to the National Crime Agency’s National Strategic Assessment 2018, up to £100 billion could be laundered through the UK annually and the problem is getting worse.
Many think of money laundering as a ‘victimless crime’ but it is anything but. In fact, it is estimated that the vast majority of the proceeds of serious and organised crime – from drugs and cybercrime through to people trafficking – is laundered through UK property, UK banks and other UK business. This rogue trading enables criminals to improve and expand their operations, transferring financial power to the underworld and ultimately funding socially destructive activities. It can put people out of work, bring businesses to financial ruin, and even cost lives.
Thousands of employees working in the accounting, property and legal sectors are at daily risk of being targeted by these criminals looking to exploit their professional skills and services to conceal the origins of the proceeds of crime. However, this also gives accountants, lawyers and estate agents a crucial role to play.
Under the 2017 Money Laundering Regulations, professionals who work in accountancy, law and property are required to file a Suspicious Activity Report (SAR) to the National Crime Agency if there are grounds for suspecting money laundering could be taking place. SARs are invaluable to law enforcement in helping tackle money laundering and other serious and organised crimes.
While money laundering isn’t always obvious, the consequences are severe. Even accidental involvement in money laundering could mean losing your licence, receiving a fine, or facing criminal prosecution.
Criminals are using sophisticated methods to clean their “dirty money”. Make sure you know how to spot the red flags and report the crime:
• Identity: Does the buyer or seller take steps, such as using intermediaries, to hide their identity, or is the beneficial owner difficult to identify?
• Resources: Does a buyer appear to be conducting a purchase that is beyond their financial means? Are they unwilling to disclose where funds are coming from?
• Documents: Is information or documentation withheld by the buyer, seller or their representative? Do any of their documents appear to be falsified?
• Behaviour: Do the buyer or seller seem unusually anxious to complete a transaction?
• Assets: Do a buyer or seller’s assets, such as their property, seem to be inconsistent with their legitimate income?
• Transactions: Are transactions unusual in their size, frequency or manner of execution, in relation to the buyer or seller’s known business type?
• Professional: Have you, or other professionals involved, been instructed at a distance, have you been asked to act outside of your usual speciality, or have you been offered an unusually high fee?
For additional information about Flag It Up or more advice on how to tackle money laundering, please visit the website flagitup.campaign.gov.uk.
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Accountants There are a range of materials you can use to promote the Flag It Up campaign and anti-money laundering advice within your organisation. This ranges from leaflets and posters to social media graphics and email signature banners. They are free to download at flagitup.campaign.gov.uk/. Materials can also be co-branded with your organisation’s logo.
InstagramLeaflet Email signature banner
Money laundering isn’t always obvious, but the consequences are severe. If you miss the signs, you could be fined or prosecuted. Don’t dirty your reputation. Submit a SAR if you are suspicious.
Dirty money. Know the signs, report the crime.flagitup.campaign.gov.uk
Money laundering is a dirty business
Partner Logo here
DirtyMoney_A5 A V3.indd 1 15/10/2018 14:21
Poster
Money laundering isn’t always obvious, but the consequences are severe. If you miss the signs, you could be fined or prosecuted. Don’t dirty your reputation. Submit a SAR if you are suspicious.
Dirty money. Know the signs, report the crime.flagitup.campaign.gov.uk
Money laundering is a dirty business
Partner logo goes here
Twitter Facebook Linkedin
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Flag It Up ToolkitContents
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LawyersThere are a range of materials you can use to promote the Flag It Up campaign and anti-money laundering advice within your organisation. This ranges from leaflets and posters to social media graphics and email signature banners. They are free to download at flagitup.campaign.gov.uk/. Materials can also be co-branded with your organisation’s logo.
InstagramLeaflet Email signature banner
Money laundering isn’t always obvious, but the consequences are severe. If you miss the signs, you could be fined or prosecuted. Don’t dirty your reputation. Submit a SAR if you are suspicious.
Dirty money. Know the signs, report the crime.flagitup.campaign.gov.uk
Money laundering is a dirty business
Partner Logo here
DirtyMoney_A5 A V3.indd 1 15/10/2018 14:21
Poster
Money laundering isn’t always obvious, but the consequences are severe. If you miss the signs, you could be fined or prosecuted. Don’t dirty your reputation. Submit a SAR if you are suspicious.
Dirty money. Know the signs, report the crime.flagitup.campaign.gov.uk
Money laundering is a dirty business
Partner logo goes here
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details
Assets
Estate AgentsThere are a range of materials you can use to promote the Flag It Up campaign and anti-money laundering advice within your organisation. This ranges from leaflets and posters to social media graphics and email signature banners. They are free to download at flagitup.campaign.gov.uk/. Materials can also be co-branded with your organisation’s logo.
InstagramLeaflet Email signature banner
Money laundering isn’t always obvious and the consequences are severe. You could be fined or prosecuted for ignoring the signs. Don’t risk it. Visit our website to find out how to submit a Suspicious Activity Report (SAR).
Dirty money. Know the signs, report the crime.flagitup.campaign.gov.uk
Money laundering is a dirty business
Partner Logo here
DirtyMoney_A5 B V3.indd 1 15/10/2018 14:49
Poster
Money laundering isn’t always obvious and the consequences are severe. You could be fined or prosecuted for ignoring the signs. Don’t risk it. Visit our website to find out how to submit a Suspicious Activity Report (SAR).
Dirty money. Know the signs, report the crime.flagitup.campaign.gov.uk
Money laundering is a dirty business
Partner Logo here
FLAG_IT_UP A4 POSTER 2.indd 1 15/10/2018 16:37
Twitter Facebook Linkedin
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details
Assets
Guidance on Suspicious Activity Reports (SARs) We have also produced guidance documents on how to submit better quality SARs for you to use and share with your employees. You can access and download the documents here: https://flagitup.campaign.gov.uk/
Guidance on submitting better quality
Suspicious Activity ReportsProvide better quality SARs by following this best practice guidance from the National Crime Agency’s UK Financial Intelligence Unit (UKFIU) and Flag It Up
Use names, surnames and dates of birthThese key identifiers are used by law enforcement to corroborate the identity of individuals. Where information is not known, using the word UNKNOWN may negate the need for law enforcement to contact the reporter to ascertain whether the information exists.If known, providing details of the main subject’s occupation and employer will assist law enforcement with judgements about the origin of funds, and whether the subject is using professional knowledge to facilitate money laundering.
Include a postcodeThe UKFIU can use postcodes to allocate SARs to the appropriate law enforcement agency. This offers opportunities to take local action and build an intelligence picture. Postcodes and international addresses are also crucial elements in the analysis of trends, such as identifying hotspots of activity.
Include relevant transactionsThe majority of Defence Against Money Laundering (DAML) SARs include transactions that relate to the request for a defence against a principal money laundering offence. It is important from an investigation point of view to include relevant transactions in the SAR, including the method of the transaction and an indication as to where the request of funds is going to and from.
Explicitly describe criminal funds or propertyThe legal requirement for a DAML request is that the reporter knows, suspects or believes that funds are criminal. The UKFIU DAML Team cannot interpret, assume or infer meaning from a suspicion. Therefore, criminal property in a DAML request should be explicitly described. Concerns or suspicions over account activity without an explanation as to why the reporter believes funds to be criminal will result in the DAML Team having to contact the reporter for clarification.
Dirty money. Know the signs, report the crime.flagitup.campaign.gov.uk
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Guidance on submitting better quality
Suspicious Activity ReportsClearly specify the ‘prohibited act’When discussing a ‘prohibited act’ the NCA refers to the proposed activity that the reporter is seeking a defence to undertake. In requesting details of the prohibited act, the NCA does not mean: • The suspected criminality being undertaken by the subject.• The particular section under the Proceeds of Crime Act 2002 for which the reporter is seeking
a defence.• A general statement that “the prohibited act for which we seek a defence is money
laundering” or similar. The prohibited act or acts of any DAML request should be explicitly stated with a clear indication of a specified time-frame. The lack of an explicit prohibited act within the context of the SAR will result in the DAML Team having to contact the reporter for clarification. Requests for a DAML must be for a specified activity or specified series of activities and should not be open ended.
Do not include unnecessary subject details in the ‘reason for suspicion’ fieldThe subject’s details need only be included in the subject fields; they do not need to be replicated in the ‘reason for suspicion’ field.
Use SAR glossary codesThis is good practice and allows the UKFIU and wider law enforcement to conduct analysis to identify money laundering trends. Where appropriate, multiple glossary codes should be used.
Include the business typeThis important element may assist an investigating officer in deciding whether or not an individual or company may have an involvement with money laundering due to the type of business they own.
REMEMBER • Plainly outline the reason for suspicion• Include a description of the property that you suspect to be criminal or the proceeds of crime• Provide a clear, specified, prohibited act that you wish to carry out within a specific time-frame.For more information and guidance on submitting SARs please visit:nationalcrimeagency.gov.uk/about-us/what-we-do/economic-crime/ukfiu
Dirty money. Know the signs, report the crime.flagitup.campaign.gov.uk
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details
Signposting
For additional resources and supporting guidance you may wish to visit the following sites:
Anti-money laundering resources such as webinars on customer due diligence and SARs can be accessed via HMRC’s guidance page.
Accountancy professionals can access the Anti-Money Laundering Guidance for the Accountancy Sector, intended for all entities providing audit, accountancy, tax advisory, insolvency or related services such as trust and company services.
Legal professionals can access the Legal Sector Affinity Group’s Anti-Money Laundering guidance for all independent legal professionals and other staff in a law practice who are involved in anti-money laundering compliance.
Property professionals can access HMRC’s Money Laundering Regulations 2017 guidance and registration guide for estate agency businesses.
Guidance on Suspicious Activity Reports (SARs)
For more detailed information on submitting SARs, please refer to the UKFIU’s user guidance http://www.nationalcrimeagency.gov.uk/publications/899-guidance-on-submitting-better-quality-sars-v2/file
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Flag It Up ToolkitContents
Introduction and Ambition
Messaging
Campaign Advice
Templates
Assets
Signposting
Contact Details
Contact
We are always interested in hearing your ideas and feedback, and are open to creating bespoke campaign content to best suit your needs.
If your organisation would like to get involved with the Flag It Up campaign, please email: [email protected].
You can also visit and link to our campaign page for more information and materials here: https://flagitup.campaign.gov.uk
