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 Money Laundering Regulations 2003

Our world is becoming increasingly regulated and litigious and we are bringing to your attention the latest legislation affecting us all – and which government is taking very seriously in its efforts to stamp out fraud, drugs and arms trafficking, and movement of terrorists funds, but has involved us all by sweeping in all aspects of possible tax evasion – and without providing a lower value at which point “criminality” is deemed to commence.

It is seemingly an imperfectly drawn law, but one to which we must all adhere until, hopefully, it can be amended in the years ahead.

The legislation was passed by government on 28 November 2003 and applies to a wide range of advisors including accountants, lawyers and estate agents together with businesses such as banks, car dealers and casinos!  It was implemented on 1 March 2004, and thereafter the legislation has profound implications on the way we will be obliged to deal with any client information we become aware of as is outlined in the next paragraph.

If, during the course of our engagement we are suspicious of any crime (including but not exclusively fiscal crime) this must be notified directly to the National Criminal Intelligence Service (NCIS) without prior reference to you.  It should be noted that this legislation overrides your expectation to client confidentiality and if such a report is made then the law prevents us from telling you that we have done so.