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PART C: ACCOUNTING AND REPORTING SYSTEMS, CONTROLS AND COMPLIANCE 
 
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(a) 
When establishing a business relationship. This is likely to be a relationship that will be ongoing 
therefore it is important to establish identify and credibility at the start. The organisation may 
have a responsibility to establish such information as the source and origin of funds that the 
customer will be using, copies of recent and current financial statements and details of the 
customer's business or employment. 
(b) 
When carrying out a high value 'occasional transaction' (a transaction that has not been carried 
out within an ongoing business relationship). The organisation should also look out for 'linked' 
transactions which are individual transactions that have been broken down into smaller, separate 
transactions to avoid due diligence checks. 
(c) 
When doubts exist about identification information obtained previously 
(d) 
When the customer's circumstances change – for example, a change in the ownership of the 
customer's business or a significant change in the type of business activity of the customer 
6.2.5 Ongoing monitoring
It is important that an effective system of internal controls is in place to protect the business from being 
used for money laundering. Staff should be suitably trained in the implementation of these internal 
controls and be alert to any potential issues. A specific member of staff should be nominated as the 
person to whom any suspicious activities should be reported, known as the Money Laundering Reporting 
Officer. 
Full documentation of anti-money laundering policies and procedures should be kept and updated as 
appropriate. Staff should be kept fully informed of any changes. 
6.2.6 Maintaining full and up-to-date records 
Businesses are generally required to keep full and up-to-date records for financial reporting and auditing 
purposes but these can also be used to demonstrate compliance with money laundering regulations.
Such records will include receipts, invoices and customer correspondence. European money laundering 
regulations require that such information be kept for each customer for five years beginning on either the 
date a transaction is completed or the date a business relationship ends. 
6.3 Categories of criminal offence 
In the UK, there are various offences relating to