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AIBU?

Share your dilemmas and get honest opinions from other Mumsnetters.

Original poster

to think I might be an accessory to a white collar crime?

194 replies

CaponeOnTax · 09/12/2022 21:59

I work in a heavily regulated profession. This has been an insanely busy week so I am only reflecting on this now, even though it all seems obvious in retrospect.

I arrived on a financial transaction mid-way through and didn’t ask about the KYC/anti-money laundering checks on all the parties (which would usually happen right at the start) but early enough.

The key document looks dodgy (USD loan, no interest) and the parties are from high-risk corruption countries. It might be legit, it might not. But I now think it could be money laundering.

I’ve finished my short involvement. I have a broad KYC obligation. So do others on the transaction and they haven’t done anything except progress the transaction.

If I say something now I could be in serious career trouble for not doing anything earlier, when in fact there may be no crime anyway.

AIBU to stay quiet and hope it goes away?

OP posts:
CatherinedeBourgh · 09/12/2022 22:01

If everyone who comes into a transaction halfway through does KYC all over again nothing would ever get done! Surely the person who initiated the transaction is responsible for that?

Dammitthisisshit · 09/12/2022 22:05

For anyone reading who isn’t sure: ‘KYC’ = know your customer - standard checks.

when you asked about the checks what was said?

if it feels off then it probably is off and so you should report.

SleekMamma · 09/12/2022 22:05

Fess up now. Tell everything now. Better to have made a process mistake than sit on knowing you should have flagged it.

Original poster
CaponeOnTax · 09/12/2022 22:05

That’s true. And that first contact person is more senior than me. Normally I just show up and do my bit.

The issue - I now realise - is that there are so many red flags that I should have asked.

OP posts:
girlmom21 · 09/12/2022 22:06

Highlight your concerns.

Original poster
CaponeOnTax · 09/12/2022 22:07

I should have said, others will get in trouble if I say anything.

OP posts:
edwinbear · 09/12/2022 22:08

OP if you work in a bank, which it sounds like, (as do I), you know full well you have to report this. You can be personally, criminally liable if you don’t. It will look much better if you flag it now, than wait until it comes out in the wash - which they always do.

girlmom21 · 09/12/2022 22:08

CaponeOnTax · 09/12/2022 22:07

I should have said, others will get in trouble if I say anything.

For also not doing the checks. It's going to be an important learning experience.

TreadSoftlyOnMyDreams · 09/12/2022 22:08

Definitely speak up. The fines and consequences would be huge if it is money laundering.

Aquamarine1029 · 09/12/2022 22:08

Report this now. Be honest and say you feel you may have missed some red flags, but in retrospect, you now have serious concerns and felt it best to bring it to their attention.

NosyNeighbour22 · 09/12/2022 22:10

Why did you end up with it half way though? Is that how it normally works? If the senior person didn’t do the checks on a potentially dodgy transaction and then handed it in to you knowing you would assume the checks have been done could they potentially be involved in some way?

Dammitthisisshit · 09/12/2022 22:10

CaponeOnTax · 09/12/2022 22:05

That’s true. And that first contact person is more senior than me. Normally I just show up and do my bit.

The issue - I now realise - is that there are so many red flags that I should have asked.

Which is why the reporting line will be different to your management line.

Don’t worry about not doing it at the time. As humans (especially females) we’re encouraged to be socialised and do what is wanted/expected of us. Sometimes we need time to process what is making us feel uncomfortable and if it’s justified or not.

But now you’ve got the benefit of hindsight I think you know what you need to do.

MRex · 09/12/2022 22:10

Safest to report it now. You know the rules that you can't tip anyone off, for all you know the more senior person is involved.

Original poster
CaponeOnTax · 09/12/2022 22:10

edwinbear · 09/12/2022 22:08

OP if you work in a bank, which it sounds like, (as do I), you know full well you have to report this. You can be personally, criminally liable if you don’t. It will look much better if you flag it now, than wait until it comes out in the wash - which they always do.

Does it always come out? I admit I am clutching at straws but the actual amount is very mundane.

I think they may well get away with it - or may be legit.

OP posts:
Original poster
CaponeOnTax · 09/12/2022 22:11

Shit. I had forgotten this bit. I can’t tell my boss?!

OP posts:
Original poster
CaponeOnTax · 09/12/2022 22:12

The No Tip-Off

OP posts:
Orangesatsuma · 09/12/2022 22:13

You need to report it. If you want to be anonymous do it as a whistleblower.

LadyLolaRuben · 09/12/2022 22:15

I work in risk but in a different industry. Its very common for checks not to be done when someone comes in mid point of the process and just runs with the transaction. Its human nature. Now you are catching up mentally you realise steps have been missed and there's a few potential issues. Yes there are learning points for everyone but you must raise the issues now you are aware.

zeddybrek · 09/12/2022 22:18

Speak up now, even if you're right it will look better than being found out later. It may be that once this is investigated there is an operational issue that has allowed this to happen, that could be corrected. This might not be the first time this has happened and other similar scenarios haven't been found out.

Essexhousehusbands · 09/12/2022 22:19

and the parties are from high-risk corruption countries

deffo report just in case. Do you have a concerns or integrity line you can call? Just say toy assume the checks have been done but you want to flag that maybe they were not.

mynameiscalypso · 09/12/2022 22:20

Report to your nominated officer or MLRO. You don't have to go through your manager (unless they happen to be the nominated officer/MLRO).

Brefugee · 09/12/2022 22:21

Surely there's a processes with breaks along the way for the KYC and other checks to be signed off though? If you have done your bit, according to the rules, you're fine.

If you go in on monday, review it and realise that red flags should have been raised, raise them.

Echobelly · 09/12/2022 22:23

Do report MUCH better later than never, I'm sure very people report until a little way in and you can always say you wanted to be totally sure. I worked until recently at a publication for people in real estate and I edited a few legal articles about the importance of reporting if you think something is wrong about a transaction. I don't think you can be in any trouble for not reporting it sooner if you do report it, but you can definitely be in trouble if the penny drops with someone else later on.

Original poster
CaponeOnTax · 09/12/2022 22:24

What if I just run the KYC process now? I think the location of the parties will raise red flags. Will I get in trouble for ‘not spotting’ the issues but carrying out the normal process for checking KYC?

OP posts:
VeggieSalsa · 09/12/2022 22:28

Report to your MLRO and ask their advice. Do not ignore.