Red flag

What should an MLRO do when a central bank fails to provide confirmation that it wishes to open an account with a UK financial institution? MLB put the question to Sue Thornhill, Director of MHA Consulting and author of the Joint Money Laundering Steering Group Guidance Notes, to Brian Dilley, Head of Deposit Taking and Financial Stability, Enforcement Division, Financial Services Authority and to a group of experienced UK MLROs.

The Joint Money Laundering Steering Group Guidance Notes (December 2001 edition) state at paragraph 4.189 that: “Where the applicant for business is a supra-national organisation, government department or a local authority, the firm should take steps to verify the legal standing of the applicant, including its ownership and its address. The firms should also obtain a certified copy of the Resolution or other document authorising the opening of the account or undertaking the transaction. Evidence that the official representing the body has the relevant authority to act should also be obtained.”