Decision Reference Number: WPCC4-0034
Lead Officer: Sara Ansell, PCC Chief Finance Officer
Chief Officer approval: T/DCC David Gardner
Date: 28/11/2024
Publication
Information in this form is subject to the Freedom of Information Act 2000 (FOI Act) and other legislation. Unless the information provided is covered by an exemption and stated to be either confidential or partly confidential, the information contained in the form will be published on the OPCC website.
Status: Non-confidential
Decision summary:
This decision notice seeks approval for the joint policy of the Police and Crime Commissioner (PCC) and Chief Constable (CC) which outlines their approach to dealing with any issues regarding money laundering. It applies to all aspects of our work and to everyone working for the Office of the Police and Crime Commissioner (OPCC) and for Warwickshire Police (WP) including permanent and temporary employees, contractors, self-employed contractors and anyone working on behalf of or undertaking work or volunteering for either activity.
I confirm that my register of interests declaration is up to date and that none of my interests preclude me from making this decision.
Signature: P. Seccombe
Date: 31/12/2024
Supporting information
1. Background information: why do we need to make this decision?
The overriding aim of the policy is to ensure the Police and Crime Commissioner (PCC), Chief Constable and their respective employees comply with anti-money laundering laws and regulations by having effective internal controls and procedures in place. The aim is to combat illegal money laundering and to prevent the misuse of police resources to launder money.
The need for an Anti-Money Laundering Policy derives from the Proceeds of Crime Act 2002 (POCA), the Money Laundering Regulations 2007 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
2. What additional documents are relied upon? Please provide a link or separate attachments.
3. What benefits will this bring, including financial, social or environmental benefits?
Having a policy in place will ensure that the issues concerning how the PCC and Chief Constable will deal with money laundering are properly outlined. The policy clearly outlines the procedure to be adopted and reporting requirements in the event of any suspicion of money laundering activity.
4. What is the impact of not approving the application?
If a policy is not in place, suspicions of money laundering may be unchallenged, and the risk of breaching money laundering legislation will increase.
5. How much will it cost? (please provide cost breakdown, including any identified savings, and include where they have been approved)
There are no direct costs arising from this policy.
6. Who has been consulted on this proposal?
The Chief Executive of the OPCC, and the T/DCC Warwickshire Police and the Director of Finance, have all received copies of the draft document and have been invited to comment and provide feedback.
7. Will this decision have an impact on any specific individuals or groups or communities?
This policy applies to all employees, temporary and agency staff, volunteers, contractors, agents, consultants, committee members and partners acting on the PCC and/or Chief Constables behalf, all of whom could potentially contravene the money laundering regulations. The policy aims to make them aware of their personal obligations and to provide them with a mechanism to raise any concerns.
8. Does this decision have legal implications? Has legal advice been sought?
The full legal implications are contained within the policy. The reporting arrangements outlined within this policy should help to ensure that all legal responsibilities and obligations are met.
Comments from the Chief Finance Officer
The previous policy is out of date and has not been reviewed for some time. This refreshed document clearly outlines the responsibilities, controls and process that are in place and the actions that should be adopted if money laundering is suspected. This will ensure that the PCC and Chief Constable and their respective employees comply with anti-money laundering laws and regulations which should prevent the misuse of police resources to launder money.
Comments from the Chief Executive and Monitoring Officer
This is an important policy in respect of delivery of the joint Corporate Governance Framework, and as such should be published and communicated with both organisation’s workforce, once approved.
