Early one morning

Cliff Knuckey may be contacted on tel: +44 (0) 20 7291 5700; email: cknuckey@managingrisc.com

“It’s 8.30am and you’ve just swallowed your first mouthful of coffee when a call comes through that there are four law enforcement officers in reception who want to speak to the MLRO.” Cliff Knuckey, Operations Director of RISC Management Ltd and a former Detective Inspector with the Metropolitan Police, who led its Money Laundering Investigation Team, set out the nightmare scenario for delegates to the Institute of Money Laundering Prevention Officers’ second annual conference. The Police come to your office and inform you that they are investigating offences in connection with money laundering. They present several production orders ( section 345 , Proceeds of Crime Act 2002 ) and a section 352 search and seizure warrant. The officers explain that they are looking into the activities of an organised crime group that has laundered drug money through your financial/professional services business. Their enquiries, they say, have also revealed that the criminals were assisted by a corrupt employee, who helped them to bypass the firm’s know your customer (KYC) checks and exploit its products. The gang members and the employee were all arrested for POCA section 327 (concealing, disguising, converting, transferring, removing criminal property from the UK) and section 328 (arrangement) offences at 7am this morning and are currently held at a various police stations. The speed at which the investigation has developed means that prior notification of the visit has not been possible, they add.