News 14th Feb 2019

Here’s why we need Suspicious Minds in order to go on together



The TI-UK blog features thought and opinion from guest writers as well as TI staff. Any opinions expressed by external contributors do not necessarily reflect the views of Transparency International UK.

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The following is a guest post from Adam Williamson – Head of Professional Standards at AAT (Association of Accounting Technicians)

Money laundering is big business. The National Crime Agency estimates that money laundering helps enable serious and organised crime that costs the UK an estimated £37 billion each year. This rises to hundreds of billions of pounds when considering international criminal money being annually laundered through UK banks and their subsidiaries. The signs of money-laundering aren’t always obvious, but the impact is wide-ranging.

Money laundered by criminals can put people out of work, and in some cases into poverty; help cause cyber attacks; and even fund terrorism and cost lives. Thousands of employees working in the accounting, legal and property sectors – among others – are at daily risk of being targeted by these criminals who use professionals in order to disguise money being laundered through the financial system.

Most accountants should be well aware of the threat that money laundering possesses, but the evidence suggests that reporting suspicious activity isn’t taken anywhere near seriously enough. Less than 8,500 Suspicious Activity Reports (SARs) were submitted by accountants, lawyers and estate agents during the 2017-18 tax year – around 5,000 of which came from accountants – despite the multitude of techniques criminals employ in order to launder dirty money through UK firms.

While accountants should have no excuse to fail to recognise the threat of money laundering, more generally there appears to be a lack of awareness of how best to tackle the issue. For example, a new YouGov poll commissioned by AAT (Association of Accounting Technicians) has revealed that in relation to the Office for Professional Body Anti-Money Laundering Supervision (OPBAS), set up a year ago to provider consistency across the 22 money laundering professional body supervisors, 54% of MPs say they have “never heard of this organisation”.

It’s in everyone’s best interests for professionals to tackle the threat of money laundering, and for this reason the Government has relaunched its Flag It Up campaign. This urges professionals in accountancy, legal and property to think with a ‘suspicious mind’ and report a SAR that could prove crucial in preventing this range of serious crimes. While the information you include in your SAR may not seem definitive in your eyes, or meet what you might think is the level of legally valid evidence, it can contain the final piece that completes the investigative jigsaw for law enforcement agencies.

AAT has over 130,000 members operating in accountancy and bookkeeping, and we recognise the responsibilities each and every member has to get this right. As we head into the new tax year, it’s been announced that the Government’s new Serious and Organised Crime Strategy will be given at least £48 million to tackle illicit finance – but ultimately the scheme will only be successful if accountants highlight when clients are overtly evasive, if funding sources are unusual or if there are discrepancies in client transactions.

It’s not a hard or particularly time-consuming job to raise a SAR, but it is an accountant’s professional and legal duty to do so. Failure to report doesn’t just impact on wider society – accountants who do not comply could face up to two years in prison, be excluded from the profession, and/or face an unlimited fine.

For additional information about the ‘Flag It Up’ campaign, or more advice on how to tackle money laundering, please visit