AML Confidential Disclosure Form

Do you suspect that a firm supervised by the Institute is in breach of anti-money laundering (aml) legislation?

Making a confidential report on suspected breaches of aml legislation

The UK Money Laundering Regulations (‘the MLRs’)[1] require the Institute to provide an effective mechanism to encourage reporting to it of actual or potential breaches of the aml legislation.  The procedure detailed below ensures that all reports made using this mechanism may be done so under the strictest terms of confidentiality. 

Irish aml legislation does not provide a specific requirement for the Institute to provide a similar mechanism but should anyone in Ireland suspect that a supervised firm is not complying with the aml legislation we would encourage you to disclose the information via the AML Confidential Disclosure Form below.

How to report to the Institute?

Click here to access an AML Confidential Disclosure Form.

Communication via the AML Confidential Disclosure Form will not be treated as a complaint.

Useful Information

The more information that you provide, the more useful this will be for the Institute. The following information would be useful:

•          Names of the individuals/firms involved;

•          Key dates;

•          Explanation of the suspected breach(es) including details of any supporting documentation; and

•          Who else knows about it.

You can disclose information in confidence without revealing your identity or contact details, although should the Institute wish to clarify any information with you, contact details would be helpful. However, you can specify that you do not want to be contacted.

It is important to note that disclosure of information to the Institute does not discharge you of any reporting obligations you might have in law.

Potential action that may be taken by the Institute

Due to the sensitive nature of the information being disclosed, the Institute will not discuss with you what action it proposes to take. The action that may be taken will depend on the nature of the disclosure. This disclosure may help the Institute in various ways including:

  • To identify a need for guidance to be issued to all supervised firms on a particular topic;
  • To target a supervised firm for an on-site visit which may result in further regulatory action being imposed;
  • To intervene in other ways to influence a supervised firm to change its business activities; or
  • To assist in a formal investigation of a supervised firm.

Your Rights

The Institute recommends that if you are considering making a disclosure as described above that you seek independent advice from a suitably qualified advisor.

The Institute does not have the power to determine whether a disclosure is protected or to intervene in employment matters and the Institute cannot provide legal advice.

[1] The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) Regulation 46(2)

Was this article helpful?