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Task guide
Internal concerns about suspicious activity
Raise a concern about a party in confidence, and how the compliance function assesses it and decides whether to report it to the Financial Intelligence Centre.
Who may do what
Raising a concern takes the right to raise one, which staff hold. Only the compliance function and the managing partner, who hold the right to see, assess and decide every concern, can read the register of concerns. The person who raised one sees that it was received and what they wrote, and nothing of what follows. The party it is about never sees it.
Raise a concern
- Open the party's record and choose Raise a concern. It is also offered on a conveyancing matter's AML tab.
- Under What you noticed, write what happened, when, and why it does not add up.
- Choose Raise concern. The dialog says the concern is seen by compliance only.
My standing in your account menu keeps Concerns you raised, each with the standing it has reached, so you know it was received. The page for a concern you raised shows it as the compliance function received it, and says that what follows stays with them. A concern raised by somebody else is not yours to read.
Assess it
Under Compliance, Clients, Concerns lists every concern with when it was raised, the party, what was noticed, its Status and the Decision. The statuses are Open, Under assessment, Closed, reported and Closed, not reported. Filter by status and by day.
Open one for Concern details: who raised it, who it is about and when. To record the compliance function's view, choose Assess and write the Assessment, then Record assessment. The assessment, who made it and when are kept with the record.
Decide it
Choose Decide. The decision is final:
- Report to the FIC: choose which party The report is about, and choose Draft the report. The report is drafted at once and falls due within the firm's filing hours; you finish it as described in Reports to the FIC.
- Do not report: choose Close concern. The concern is closed as not reported, and the assessment stays on record.
A decided concern shows the decision, the report it led to and the FIC's reference once the report is filed.
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