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International initiatives, and bodies and jurisdiction legislation…
International initiatives, and bodies and jurisdiction legislation
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Knowledge
actual subjective knowledge – you definitely know some fact(s), e.g. you know the money comes from drug deals
wilfully shutting your eyes to the obvious (Wilful Blindness). This is where you don’t ask questions because you think they may raise information that will mean you have to make a report; here you could be seen as having ‘known’ but turned a ‘blind eye’ – for example you think the money comes from a crime but you don’t make any further enquiries
wilfully and recklessly failing to make such enquiries as a reasonable and honest person would make.
Suspicion
‘a degree of satisfaction not necessarily amounting to belief but at least extending beyond speculation as to whether an event has occurred or not’
An employee who has become suspicious should make a report to the Money Laundering Reporting Officer (MLRO) as quickly as possible.