It is important that you understand the definition of financial crime as this does not just cover money laundering. The Financial Services and Markets Act 2000 (FSMA) defines financial crime as including ‘any offence involving;

 

a) fraud or dishonesty;

b) misconduct in, or misuse of information relating to, a financial market; or

c) handling the proceeds of crime’.

 

According to the FCA, there are a number of different ways in which someone can be involved in financial crime. For example;

 

1. A firm directly suffers from a financial crime if, for example:

 

• The firm is defrauded by an employee (e.g. a company director embezzles corporate funds);

• The firm is defrauded by organised criminals.

 

2. A firm is exploited as a vehicle for financial crime if, for example:

 

• Criminals use the firm’s services to launder the proceeds of crime;

• A firm’s customer makes payments to terrorists;

• Customer data held by the firm is stolen and used to commit identity theft.

 

3. A firm, or a representative of the firm, carries out a financial crime, perhaps in collusion with another party if, for example:

 

• A member of staff knowingly overstates the income of a customer to obtain finance for which the customer was not otherwise eligible.

 

Financial crime is therefore considered relevant to the following areas;

 

• Anti-money laundering

• Financial sanctions

• Data security

• Fraud and bribery controls

 

Just Asset Finance Ltd has put in place appropriate systems and controls to identify, assess, monitor and reduce the risk of being used for financial crime and of any staff being involved in financial crime.

 

31.1. Money Laundering Reporting Officer (MLRO)

 

The Money Laundering Reporting Officer for Just Asset Finance Ltd is Nathan Golding.

 

If you need to report any suspicious activity, your report should be referred to Nathan Golding.

 

 

31.2. Identification and verification

Our underlying obligation is that we must be satisfied and can demonstrate that the person we are dealing with is who they claim to be, therefore, evidence of the client’s identity must be obtained and recorded. It is important that evidence is not considered in the light of existing knowledge and details found on other documents provided. Consideration should be given to whether the details are reasonable.

 

 

31.3. Customer screening

In addition to verifying the customer's ID we are also required to ensure that the customer does not appear on any financial sanctions lists or are Politically Exposed Persons (PEPs).