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20 October 2017 / Jonathan Fisher KC
Issue: 7766 / Categories: Features , Criminal
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Suspicions, privacy & money laundering

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Jonathan Fisher QC & Anita Clifford put the new arrangements for money laundering under the spotlight

  • The new ability for regulated persons to share information relating to a money laundering suspicion.
  • The ability for a court to extend the moratorium period when a suspicious activity report is filed.

The Criminal Finances Act 2017 has introduced important changes to the anti-money laundering regime for the reporting of suspicious activity under Pt 7 of the Proceeds of Crime Act 2002 (POCA 2012). Two changes which will have a significant practical impact on lawyers, estate agents and financial sector professionals, who comprise the regulated sector, are the new ability for regulated persons to share information relating to a money laundering suspicion, and the ability for a court to extend the moratorium or ‘no action’ period applying to a matter when a suspicious activity report (SAR) is filed.

Underlying both new frameworks is an intention to make the investigation of criminal property laundered through the UK easier. However, the open-textured nature of some of

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