Government evasion and Credit Unions

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Attempting to transform cash from criminal action into

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Tax evasion and Credit Unions Janice Parker

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What is Money Laundering Covers an assortment of exercises including: Trying to transform cash from criminal movement into "clean" cash (great IRS evasion) ‏ Handling the advantage of violations, for example, burglary, extortion and expense avoidance Handling stolen merchandise Criminals putting the returns of their wrongdoings in different monetary items Regulations likewise cover Combating the Financing of Terrorism (CTF) ‏

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Does it happen in Credit Unions? YES!

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What Should Credit Unions Do? Know about and take after the Guidance given by the Joint Money Laundering Steering Group (JMLSG) ‏ Appoint a Money Laundering Reporting Officer Have an executive who has general duty regarding Money Laundering anticipation Apply a 'Hazard Based' approach

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Risk Activity in Credit Unions Money Transfers to 3 rd Parties Large One-Off exchanges – e.g. sudden advance reimbursement 3 rd parties paying in real money for the benefit of the part Unusual advance or funds designs (counting standard huge installments) ‏ "Smurfing" Reluctance to give narrative confirmation of personality when opening a record Regular solicitations for advances that are soon reimbursed

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Know Your Customer This is VITAL Not just about knowing individual individuals, yet realizing what's "ordinary" for your individuals general It is conceivable (and judicious) to unpretentiously utilize cautious addressing of individuals to distinguish where cash has originated from – it's recommended in the Specialist Credit Union Guidance from JMLSG

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The Money Laundering Reporting Officer (MLRO) ‏ Responsibilities: Establish and keep up preparing program for staff and volunteers on Money Laundering Receive inside reports of doubt of IRS evasion Investigate suspicious reports inside and keep records of their examinations Make outer reports to SOCA when suitable Obtain and apply important Govt and Financial Action Task Force (FATF) discoveries Report to the administration council at any rate once every year.

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Internal Reporting All staff and volunteers should have the capacity to perceive government evasion and know how to report suspicious movement. Utilization of standard Money Laundering Reporting Form – a similar shape can be utilized to make "negative" reports. In the event that volunteer, and so forth, in uncertainty they ought to talk about it with a more senior individual inside the CU however care ought to be taken to abstain from "tipping off"

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External Reporting The MLRO ought to guarantee that any inner report is managed rapidly and secretly If having explored the accessible data the MLRO concurs with the doubt they MUST report it quickly to: Serious Organized Crime Agency (SOCA) utilizing a Suspicious Activity Report (SAR) Form SOCA lean toward web based reporting!

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Please recall... In the event that you think there will be more exchanges (in or out) you ought to demand "assent" on the SOCA report If utilizing internet reporting and don't get an affirmation of receipt then ring the helpdesk on 0207 238 8282 The Financial Intelligence Helpdesk will offer exhortation to MLROs if necessary

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You've made a report – What happens next? Without a doubt not in particular… … . On the off chance that you've requested "assent" you ought to be reached by SOCA inside 7 days to illuminate you if assent conceded or denied

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Consent. In the event that SOCA give assent you may permit exchanges (or a particular exchange) on the record not surprisingly. In the event that assent is rejected this goes on for 31 days. You might be presented with a court "Limitation Order" identifying with the record before the 31 days is up.

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JMLSG Guidance on ID & Risk How much ID proof to request relies on upon the hazard however the direction says that for the greater part of credit union individuals a visa or photocard driving permit is adequate Customer Due Diligence Enhanced Due Diligence

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Hierarchy of ID Documents (1) ‏ Single Document/Standard level Issued by Government Departments, organizations or courts Passport Photocard Driving License Firearms or Shotgun License Should be acquired as a rule

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Hierarchy of ID Documents (2) ‏ More Documents Required Issued by Public Sector bodies or nearby powers Benefit Book or letter Pension Book or Letter from DWP Council Tax Bill Utility Bills (yet not from web) ‏

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Hierarchy of ID Documents (3) ‏ Certain Documents issued by the monetary administrations segment Bank Statement (not from web) ‏ Credit Card Bill (not from web) ‏ Those issued by others subject to Money Laundering Regulations Letter from a specialist Issued by Others Rent proclamation or Tenancy understanding

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Unable to give standard proof Rented convenience Legal, mental or physical powerlessness to deal with possess issues Individuals dependant on the care of others Dependant life partners Students Refugees Migrant laborers Prisoners/ex wrongdoers

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Possible Documents Letter from DWP in regards to annuity or advantages Letter from Matron of Care Home Gender reassignment data School College or Care Institution FSA decides say that individuals who can't sensible be required to give standard proof of personality ought not be irrationally denied access to budgetary administrations

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Child Accounts All Child Accounts require ID Birth Certificate Passport NHS Medical Card Child Benefit Documentation Child Tax Credit Documentation Child Trust Fund Letter PLUS ID for grown-up (on the off chance that you don't as of now have fitting ID for them) ‏ NOTE – For school construct accounts a letter in light of headed paper from the school expressing; the name of the tyke, their private address and affirmation that they are an understudy at the school, is considered as adequate ID

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Monitoring Member Activity Need to set up a procedure for checking records to highlight bizarre exchanges Simple approach could include: Investigating stores over a limit Frequency of stores Members whose stores seem whimsical A more modern approach might be required – recollect 'chance based' Unusual does constantly mean suspicious – it's only a beginning stage

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Training Volunteers, Staff and Directors Who is the MLRO? What are the systems? What are abnormal exchanges? Tax evasion Regulations The FSA Rules and Industry Guidance MLRO The Law identifying with Money Laundering and psychological oppressor financing

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Training (2) ‏ Records should be kept of the preparation given to, or embraced by volunteers Signing in sheets for instructional courses Volunteer record sheets All volunteers, staff and so forth ought to get IRS evasion preparing in any event once at regular intervals

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Record Keeping Customer ID – 5 years after the end of the relationship (can be reference numbers not really duplicates of unique docs.) ‏ Transaction subtle elements – 5 years after end of relationship Any Money Laundering Reports Information NOT followed up on Training Records

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Penalties Activity Penalty Assisting anybody you know or suspect of Money Laundering Up to 14 years detainment as well as a fine Up to 5 years detainment and additionally a fine Informing anybody that they are under doubt or being explored Deliberately not reporting tax evasion doubt Up to 5 years detainment or potentially a fine Failing to agree to any of the controls Up to 2 years detainment and additionally a fine

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Useful Resources: Joint Money Laundering Steering Group http://www.jmlsg.org.uk Serious Organized Crime Agency http://www.soca.gov.uk Information on making a SAR http://www.soca.gov.uk/financialIntel/suspectActivity.html Financial Action Task Force www.fatf-gafi.org

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