The ATT/CIOT’s AML Whistleblowing Policy
ATT/CIOT strongly supports the UK government’s drive to combat Money Laundering and Terrorist Financing and feel it is paramount for our members and the public to help the fight. The ATT/CIOT encourage whistleblowing by both our members and members of the public where a concern arises that may involve risk of malpractice or wrongdoing and specifically in relation to AML compliance. Whilst this is typically witnessed by employees in the workplace it may be seen by members of the public in interaction with firms of tax advisers and accountants and the staff of a firm in their interaction with others in the same profession. Note that whistleblowing is distinct from a complaint which arises where a complainant has a grievance towards someone else, or dissatisfaction about a service that has been received.
If you have any concerns about AML or potential breaches of the Money Laundering Regulations 2017 (as amended) in which another person might be taking part, please consider the following action:
If you have concerns at work, you should first consider reporting suspected wrongdoing through the channels available to you at your firm.
Your firm’s whistleblowing policy, should it have one, will assist you in determining whether and how you can report your concerns internally. If in doubt about what procedures to follow, consult with your HR department.
In addition, where applicable, your money laundering reporting officer (MLRO) may be best-placed to determine what to do with the information.
Reporting to the ATT/CIOT
If you come across anybody that under the Money Laundering Regulations 2017 (as amended) appears to be ignoring their obligations (including not appearing to be supervised at all), or is involved in wrongdoing don’t ignore it. If you think they are a member of ATTor CIOT (you can check whether they are on Find a CTA or Find an ATT) and you want to report it confidentially, contact our whistleblowing team whistleblowing [at] ciot.org.uk.
Alternatively, make a complaint to our independent disciplinary body, the Taxation Disciplinary Board (but note that their usual procedure is to contact the party about whom you are complaining to give them the opportunity to respond).
The more detail you can give our whistleblowing team, the easier it will be for them to consider what our response should be.
The following things are useful:
- the names of any individuals involved in the misconduct
- any key dates you know about
- the ‘how’, ‘what’ and ‘where’ of any supporting documents or evidence
- the type of wrongdoing and who else knows about it.
You don’t need to give us your identity or contact details, although it would make it easier if we need to clarify things or ask for further information. If you have provided contact details then we may proactively contact you if we require any further information, unless you specifically ask us not to.
We aim to treat anyone (whether a ATT/CIOT member or member of the public) that contacts us on ‘whistleblowing’ matters with confidentiality. Unless you choose to disclose your identity to the firm or individual concerned, we will make sure that it is protected, unless a court asks us to provide this information. All information received on such matters is stored securely with limited and protected access.
Reporting to HMRC
If the person you are reporting is not a member of ATT/CIOT, you can check whether they are supervised for AML by HMRC and if so, you can refer them to HMRC.
If you can’t find the name of a known supervisor, please contact the HMRC MLR Registration Team on their confidential enquiry line +44 (0)1702 366 312 or advise HMRC through their Central Intervention Team email inbox MLRCIT [at] hmrc.gsi.gov.uk.
Additional disclosure protection
For advice on protection available under the Public Interest Disclosure Act 1998 and the Enterprise and Regulatory Reform Act 2013, contact Protect.