POCA now states that a voluntary disclosure made in good faith by a Regulated Firm does not breach an obligation of confidence owed by the person making the disclosure, or any other restriction on the disclosure of information, however imposed.
The new legislative provisions add to the list of points for Regulated Firms to consider in this context. Identify the person or persons to whom it is requested that the information is disclosed.
Hades Investments LLC is incorporated in Delaware and invests in the oil industry in Nigeria and has the benefit of several oil prospecting licences which it operates as joint ventures with other entities.
The transfers are brought to the attention of the Money Laundering Reporting Officer "MLRO" of Saturn Bank because Mr Zeus is the brother of a high-ranking official in an oil-rich Nigerian state and is subject to enhanced customer due diligence because he is a family member of a politically exposed person "PEP".
A joint disclosure report is The new provisions are complex and not user-friendly. The Recipient may disclose information, if the following conditions are met: The MLRO notes that there are reasonable grounds to suspect money laundering in the same terms as the Disclosure Request.
It also provides marketing and project management services in the oil extractive industry. The MLRO asks for additional information regarding Hades Investments LLC, including who the ultimate beneficial owner is, where the entity is incorporated, the duration of its relationship with Cronos Bank and its source of wealth and source of funds.
Implications As discussed above, the new information sharing scheme was introduced with the aim of improving the provision of SAR intelligence by providing consolidated information to the NCA.
It remains to be seen how effective this will be in practice: Making a Super-SAR Following the disclosure of information by the Recipient in response to a Disclosure Request, the Recipient and the Requesting Firm may decide to produce a joint disclosure report i.
Click here to download PDF. This will allow the NCA to examine several stages of a money laundering scheme without extensive cross-referencing.
A report to an NCA authorised officer; 2. Provide such other information as the person making the Disclosure Request thinks appropriate for the purposes of enabling the Recipient to determine whether the information requested ought to be disclosed.
There are concerns that the sharing of information under the new regime may have data protection implications.
A statement that the request is made in connection with a suspicion that a The firm case study is engaged in money laundering and identify the person suspected if known ; 2.
A report which satisfies the following content requirements: Condition 2 is that: The MLRO notes that it is suspected that Mr Zeus may be engaged in money laundering and outlines the reasons why - Mr Zeus is the brother of a high-ranking official in an oil-rich Nigerian state and has received three transfers of U.
Condition 4 is that the Recipient must be satisfied that the disclosure will or may assist in determining any matter in connection with a suspicion that a person is engaged in money laundering. Condition 3 is that, before the Recipient makes the disclosure, the Required Notification, as described above, has been made to the NCA.
Condition 1 is that: Although Mr Zeus is a successful business person, the transfers appear to be irregular in the context of the normal activity on his account. Responding to a Disclosure Request Having received a Disclosure Request, the question for the Recipient is whether or not to disclose information, as the regime is voluntary rather than mandatory.Case Studies: Most Recent.
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