Issue - meetings

The Head of Finance introduced the report setting out an updated version of the Council’s Anti-Money Laundering Policy and Guidance to various stakeholders on how to prevent, detect and report cases of fraud through money laundering.  The Head of Finance explained that:

·  The first draft of the updated Policy was reported to the Committee in January 2020 when it was agreed that the document should be reviewed in the light of comments made by Members.  Since then, the Finance Manager had reviewed the document in consultation with Councillor Adkinson and the main amendments following the review were:

Paragraph 2.2 – Removal of a named Officer as the Money Laundering Reporting Officer, leaving it as the Director of Finance and Business Improvement (S151 Officer) which meant that it would not be necessary to amend the Policy in the event of staff changes.

Paragraphs 3.2 and 4.1 – Reducing the large volume/value cash transactions for single transactions and/or two or more transactions which appear to be linked from £10,000 to £5,000.

Paragraph 4.2 – Keeping a register of all cash transactions over £2,000 to review who is making large cash payments to the Council.

·  Amendments had also been made to make the document gender neutral.

·  The document now reflected best practice guidance from the financial and legal professions, including CIPFA.

In response to questions, the Director of Finance and Business Improvement advised the Committee that:

·  This Policy related to cash transactions so payments through a bank for example would not count.  So far as making linked payments was concerned, there was a risk that they might not be identified but he would hope that seeing a number of similar amounts from the same payer would be flagged up and it would then be treated as a cash amount of over £2,000 if it could be identified that the payments were linked.

·  Although the Policy did not specifically say so, Officers would consider the need to undertake the sort of risk assessment required by Regulation 18 of the Money Laundering Regulations 2017.

During the discussion on this report, it was pointed out that paragraphs 1.4 and 3.1 of the revised Policy should be amended to correctly reflect the Money Laundering Regulations 2017.

The Chairman thanked Councillor Adkinson for his work on the updated Policy.

RESOLVED:  That subject to paragraphs 1.4 and 3.1 of the Policy being amended to correctly reflect the Money Laundering Regulations 2017, the Council’s updated Anti-Money Laundering Policy, attached as Appendix A to the report of the Head of Finance, be adopted and the Director of Finance and Business Improvement (S151 Officer) be confirmed as the Council’s Money Laundering Reporting Officer.