You must familiarise yourself with the Firm's Anti-Money Laundering and Sanctions Policy and Internal Reporting Procedure.
Where you know or suspect money laundering or terrorist financing, you must make a formal internal report without delay using the prescribed reporting form on Keyed-In. Concerns relating to sanctions, proliferation financing, fraud, bribery, tax evasion, or other financial crime must be escalated without delay using the applicable procedure or, where uncertain, directly to the MLRO.
A request for guidance is not the same as a formal report. An email, Teams message or telephone call will be treated as a request for guidance and not as a formal internal report unless the MLRO expressly confirms otherwise. While lawyers are encouraged to discuss concerns with the MLRO at an early stage, the existence of uncertainty should not delay a formal report where the reporting threshold has been met.
Reports submitted through the prescribed process are confidential and will be reviewed by the MLRO, who will determine what action should be taken.
Lawyers must not discuss a report, the existence of any suspicion, or any related investigation with the client or any third party without guidance from the MLRO. Doing so may amount to tipping off or otherwise prejudice an investigation.
Legal professional privilege must always be considered. If information may be subject to legal professional privilege, contact the MLRO immediately and do not make your own determination as to whether the information should be included in a formal report. The need to consider privilege must not result in the concern being ignored or left unaddressed.
Once a formal report has been made, or the MLRO directs that work should pause, you must not take any further step affected by the concern, receive, transfer or return relevant funds, or communicate with the client or another party about the concern unless authorised by the MLRO.
The MLRO will determine whether any report should be made to law enforcement and will provide guidance regarding any continuing restrictions on the matter.