Tipping Off
- 01:51
The legal and ethical implications of disclosing any information related to suspicious activities or transactions that could potentially alert a customer that they are being investigated for money laundering.
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Compliance money laundering Risk managementTranscript
An STR can potentially be compromised if the client becomes aware that they are being investigated for potential money laundering offenses. Because of this, it is also a criminal offense to inform a client that they are being investigated for money laundering referred to as tipping off. Because tipping off is a criminal offense. Financial service providers and their employees must stay alert to avoid tipping off a client without meaning to either through words or actions.
So what does tipping off sound like? What would an employee have to say to a customer to tip them off? For example, the following could well constitute tipping off the three transactions across your account last Friday look suspicious to us and we have started an investigation. How can an employee avoid this situation? What could they have said if they are tasked with asking the customer for an explanation for certain transactions? Here's an example of what wouldn't constitute tipping off. Please may I know the purpose of the transactions across your account last Friday. This isn't the end of this issue, though such a question may result in the customer challenging the employee asking for the firm's reasons as to why they have asked for this information by saying, for example, why do you need to know? Or it's none of your business.
It's important to note that the employee should still not indicate that an investigation is underway, but they should rather remind the client that financial service providers have a duty to understand the purpose of customer transactions and the overall purpose of the account. Transaction inquiries are routine and initiated whenever financial services firms see transactions that don't match the normal pattern.