Those of you who know me well will be aware of my fondness for consultations. If a regulator or government agency announces that they are taking public soundings on anything to do with financial crime, I’m there. Usually, if you look hard enough, you can find a paragraph in the consultation document that explains who they would like to hear from, and the last bit will say something like “or any other party with an interest in this matter” – and that’s how I get permission to stick my oar in, add my two-penn’orth and generally sound off.
So imagine my delight when I returned from holiday recently to find that the UK Sentencing Council (who are responsible for promoting consistency in sentencing in the UK courts, generally by issuing sentencing guidelines – I use them regularly myself when I sit as a magistrate) has launched a consultation on proposals for updating guidance for judges and magistrates when sentencing fraud, bribery and money laundering offences – be still my beating heart! You may be surprised to hear that this is actually the first time that sentencing guidance has been proposed at all for bribery and money laundering, while the fraud bits are being substantially updated. You have until 4 October to respond, and you can do it online or by snail mail. And if – like me – you prefer to have a paper copy of the consultation document to mark up with your red pen or outraged highlighter, you can download and print a PDF, or just phone the nice people at the Sentencing Council on 020 7071 5793 and they will send you a hard copy.
Apart from being great fun, it’s actually rather important, as sentencing is the endgame: there’s no point in us putting all of this effort into due diligence, record-keeping and reporting, and then the FIUs busting a gut investigating our suspicions, if money launderers get off with the proverbial slap on the wrist. So get your oar in too; here’s that magic sentence from the Sentencing Council press release: “Anyone can respond whether they are criminal justice professionals, business representatives, victims or members of the public with an interest in fraud issues.” That’s us, folks!
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