Glossary

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Assisting - a criminal offense to acquire, use, possess, conceal, disguise, convert, transfer or remove criminal property from the jurisdiction, or to enter into or become concerned in an arrangement to facilitate the acquisition, retention, use or control of criminal property by another person. An offense punishable by 14 years imprisonment and/or an unlimited fine.

Beneficial Owner - the individual who ultimately owns or controls the customer on whose behalf a transaction or activity is being conducted.

Criminal Conduct - conduct which constitutes an offense in any part of the United Kingdom, or would constitute an offense in any part of the United Kingdom if it occurred there.

Criminal Property - property which constitutes a persons benefit from criminal conduct or which represents such a benefit (in whole or part and whether directly or indirectly), and the alleged offender knows or suspects that the property constitutes or represents such a benefit.

Customer - in relation to an FSA-regulated firm, a customer is a person who is using, or may be contemplating using, any of the services provided by them.

Customer Due - a list produced by HMT outlining sanctions against countries, individual or entities where it is not permitted to undertake business with.

Deputy MLRO - appointed by the MLRO to undertake duties in relation to anti-money laundering. See definition for MLRO.

Enhanced Due - for some particular customers, products or transactions, simplified due diligence (SDD) may be applied; in the case of higher risk situations, and specifically in relation to customers who are not physically present when their identities are verified, correspondent banking and PEP, enhanced due diligence (EDD) measures must be applied on a risk sensitive basis.

Failure to Report - a criminal offense for persons working in the regulated sector of failing to make a report where the have knowledge or suspicion of money laundering, or reasonable grounds for having knowledge or suspicion, that another person is laundering the proceeds of any criminal conduct, as soon as is reasonably practicable after the information came to their attention in the course of their regulated business activities.

FATF - the Financial Action Task Force (FATF) is an inter-governmental body whose purpose is the development and promotion of national and international policies to combat money laundering and terrorist financing.

Fraud - fraud is a deception made for personal gain or to damage another individual. Fraud is a crime, and is also a civil law violation.

FSA - Financial Services Authority (FSA), the U.K. regulator of the financial services industry.

H M Treasury - responsible for advising firms of additions to the financial sanctions list.

Identification (ID) - ascertaining the name of, and other relevant information about, a customer or beneficial owner.

MLRO - the MLRO is responsible for the oversight of all aspects of the firms AML/CFT activities and is the focal point for all activity within the firm relating to anti-money laundering.

Nominated - a person in a firm or organization nominated by the firm or organization to receive disclosures from others within the firm or organization who know or suspect that a person is engaged in money laundering.

PEP - Politically Engaged Person (PEP) is an individual who is or has, at any time in the preceding year, been entrusted with prominent public functions, and an immediate family member, or a known to close associate, of such persons.

POCA - Proceeds of Crime Act 2002. The Proceeds of Crime Act 2002 (POCA) consolidates and extends the exisitng U.K. legislation regarding money laundering.

Prejudicing - a tipping-off offense is committed if a person knows or suspects that an offense has been made by an individual and informs them they are under investigation or provides information to the person under suspicion which is likely to prejudice any investigation.

Proceeds of - Proceeds of Crime Act 2002. The Proceeds of Crime Act 2002 (POCA) consolidates and extends the existing U.K. legislation regarding money laundering.

SAR - Suspicious Activity Report (SAR), a report made by the MLRO, Deputy MLRO or Nominated Officer to SOCA.

SOCA - Serious Organized Crime Agency, the U.K.'s Financial Intelligence Unit (FIU)

Terrorist - the Terrorism Act establishes a series of offenses related to involvement in arrangements for facilitating, raising or using funds for terrorism purposes.

Tipping Off - a tipping-off offense is committed if a person knows or suspects that an offense has been made by an individual and informs them they are under investigation or provides information to the person under suspicion which is likely to prejudice any investigation. Punishable by 5 years imprisonment and/or an unlimited fine.

U.K. Driving - old style paper licenses ceased being produced in March 200. New style photo card licenses were produced from July 1998. Drivers code: first and last numbers are the last two digits of the year of birth 13 08 45 = 4 - 5; fourth and fifth numbers are the day of birth 13 08 45 = 4135; second and third numbers are the month of birth 13 08 45 = 408135. But for a female you add 50 to the month of birth so in the above example the code would become 458135.

U.K. Passport - the following rules apply: valid for 10 years (but may be a shorter period if a replacement) and contains 32 pages, all bound together. Reference number appears twice, in the top right hand corner and as the nine numbers of the code on the bottom left hand side. Top line code should read P GBR surname first name second name.