Coyne Recruitment is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with the Money Laundering Regulations 2007.
Risk sensitive policies and procedures must be established in order to anticipate and prevent money laundering and terrorist financing. A risk sensitive or risk-based approach is where businesses assess the risk of candidates laundering money through their business. Businesses may take the starting point that most candidates will not launder money but will identify criteria that would indicate a higher risk of money laundering – e.g. where there is no face-to-face meeting to establish identity.
How we manage the risk Coyne Recruitment is committed to staff training in anti-money laundering legislation and this is also covered as a part of the Induction training courses.
Coyne Recruitment Directors have responsibility to receive and review internal reports regarding suspicious behaviours and will forward reports to National Crime Agency as necessary.
Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risks of our business being used to launder money or fund terrorism. All candidates who are placed by Coyne Recruitment must be identified fully with evidence of identity being photographic. Should a face to face meeting not take place then enhanced due diligence procedures will need to be adopted by asking for additional information or evidence to establish the candidate’s identity and ensuring that the documents supplied are certified.
If the verification of the candidate’s identity is done by documents this should be based on a government issued document with the candidate’s full name and photo with either the candidate’s date of birth or residential address such as:
1. Valid passport
2. Valid photocard driving licence
3. National identity card
4. Firearms certificate
A government issued document (without a photo) which includes the candidate’s full name and supported by secondary evidence:
1. Old style driving licence
2. Recent evidence of entitlement to state or local authority-funded benefit such as housing benefit, council tax benefit, pension, tax credits
Supported by secondary evidence such as:
1. A utility bill
2. Bank or building society statement
3. Most recent mortgage statement from a recognised lender
For candidates other than private individuals
For candidates who are not private individuals, such as corporate candidates and private companies, the business must obtain information that is relevant e.g. company registration number, registered address and evidence that the individuals have the authority to act for the company – a search at Companies House will reveal details of directors and company secretary.
Suspicious Activity Reporting
A report will be made if a member of staff/ the nominated officer thinks that there is a possibility, which is more than fanciful, that a person is or has been engaged in money laundering or terrorist financing. The report will be made to the Directors who, should they be satisfied that there are grounds to suspect money laundering or terrorism before reporting their suspicions to the National Crime Agency.
What is Suspicious Activity?
This list is by no means exhaustive:
• Reluctance to provide details of their identity
• Candidate is trying to use intermediaries to hide their identity or involvement There appears to be no genuine reason for the candidate using the business’s services
• Money is paid by a third party who does not appear to be connected with the client
• The client requests payment to a third party who has no apparent connection with the candidate
• A cash transaction is unusually large and the client will not disclose the source of funds.
• A transaction is carried out for less than market value with an unconnected person
Should a report be made then it is important that this fact, and any information about the transaction in question, is kept confidential
The following records are required to be kept for 5 years:
• Copies of, or references to, the evidence obtained of a candidate’s identity for five years after the end of the candidate relationship, or five years from the date when the transaction was completed.
• Supporting records relating to a candidate relationship or occasional transaction for five years from the date when the transaction was completed.
The purpose for keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations.
Coyne Recruitment acts as an employment agency for the purposes of the Conduct of Employment Agencies and Employment Business Regulations 2003.
This information has been taken from and condensed from the OFT Money Laundering Regulations 2007 Core guidance issued under Crown Copyright 2007