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
