Agenda item

Agenda item

Anti-Money Laundering Policy Update

Report of: The Head of Financial Services

 

Purpose of report: To present the updated Anti-Money Laundering (AML) Policy for approval and to outline the key changes compared to the previous version, last reviewed in 2019.

 

Recommendation(s):

·       That the policy be approved and adopted into Oxford City Council’s policy framework.

 

 

Minutes:

Scott Warner, Counter Fraud Manager, was present to answer questions.  

  

The Counter Fraud Manager introduced the updated policy to the Committee and noted a minor correction on the cover of the report. He clarified that rather than recommending the policy be adopted as part of the Council’s policy framework, it is recommended that the policy sits outside of the framework within a suite of Council documents aimed at protecting financial interests. The Counter Fraud Manager explained that the anti-money laundering report forms part of the Council’s governance framework and ensures compliance with legal obligations in relevant regulations and makes clear the ongoing commitment to preventing financial crime. The policy was last reviewed in 2019 and has been updated due to changes in national legislation and the Council, including a move to a cashless transaction environment and changes to emerging risks.  

  

The Counter Fraud Manager outlined the main areas of the report which have bene updated since 2019: 

·       Additional clarity on inclusion of contactors and agency staff with compliance into procurement contracts  

·       References to legislation updated. 

·       New and updated acts linked to money laundering. 

·       Policy provisions for the cashless approach which address risks on transactions below £5000 (the current reporting threshold). 

·       New provisions for risks associated with crypto assets in order tofutureproof the policy.  

  

The Counter Fraud Manager assured the Committee that the updated report aligns the Council with current regulations and standards and better equips the Council to manage emerging risks whilst reflecting a proactive stance to safeguarding public funds. 

 

Councillor Smith queried the clarification regarding the recommendation. The Counter Fraud Manager explained that the recommendation requests approval for the policy in support of the Council’s financial procedures and governance procedures, but not as part of the wider policy framework.  

 

Councillor Ottino queried whether the £5000 transaction threshold is outlined through legislation, and how often the Council encounters transactions above the threshold. The Counter Fraud Manager explained that this is a condition of legislation and that all transactions beyond the threshold must be reported to the National Crime Agency via the Suspicious Activity Report. He noted a handful in the last year which required reporting.  

  

Councillor Smith noted the repetition of this topic in previous meetings and an example of council tenants conducting money laundering attempts. On this basis she sought clarification on whether the updated policy would cover similar activity. The Counter Fraud Manager assured the Committee that attention would always be paid to matters or events which directly impact the Council or puts finances at risk, but noted that each case must considered on its own merits and the police can be involved if necessary. 

Councillor Ottino referred to business rentals and queried how checks to ensure payments are being taken from legitimate sources are carried out. The Counter Fraud Manager assured the Committee that a suite of due diligence checks is utilised by the relevant team, and where concern exists, the finance team is contacted for approval from the National Crime Agency.  

  

The Chair sought clarity on how many cash transactions take place each year to which it was confirmed to be very few.  

 

The Committee: 

a.    Approved the Anti-Money Laundering Policy 

b.    Delegated to Officers to adopt the policy into Oxford City Council’s financial and governance procedures. 

 

  

The Counter Fraud Manager left the meeting. 

 

 

Supporting documents: