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Money laundering

We will not take part in any money laundering activity, and do all we can to stop it

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What it's all about

Money laundering allows criminals, including terrorists, to take money they have gained through crime and pass it through a series of complex and deliberately obscure banking and commercial transactions, so the illegal origins are concealed and the money is “cleaned” – like a laundry cleans dirty clothes. 

The criminals then have access to what now appears to be legitimate money. 

It’s a highly corrupt and toxic process that finances terrorism, corrupt politicians, drug barons and criminal gangs, and destabilises societies - placing them in the grip of corruption.

There are two vital things we are totally committed to doing to prevent money laundering taking place in any part of our business: we follow all the rules; and we stay alert. If we suspect anything – we report it.

“It’s not just about stopping cheats. It’s about stopping things like terrorism.”

What we all need to know and do

  • To try to prevent money laundering from happening inside countries and across borders, there are national and international anti-money laundering, corruption and terrorist financing laws and regulations. We always make sure that we follow these in all our transactions.

  • We only do business with customers and third-parties involved in legitimate business activities, and ensure all funds and payments are from legitimate sources.

  • We ensure that third-parties are screened to assess their identity and legitimacy before contracts are signed or transitions occur.

  • We don’t just assume the checks have been completed. One of the big potential ways money laundering can happen is if we fail to check or update screenings periodically. By keeping up to date, we keep Serco and our colleagues from being at risk.

  • We stay alert – and maintain controls to detect, investigate and report suspicious activity.

  • If at any point we have any suspicions about actual or potential money laundering activity, we report it at once to our Divisional Ethics & Compliance Lead or Legal Department.

 What are the warning signs?

  • We also take care to look out for warning signs of money laundering. Here are some of them:

    • If a customer or an organisation paying us asks to take payments in a form that is outside the normal terms of business.

    • If a customer or an organisation paying us overpays Serco from multiple bank accounts or from bank accounts overseas when they are not a foreign customer or an organisation paying us.

    • If the payment is made in cash when it’s normally made by cheque or electronically.

    • If it’s received from other third-parties.

    • If an advance payment is made when that’s not part of normal terms of business.

    • If refunds are requested to a different bank account from where the payment was made.


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We had this team of labourers who worked via an agency. The project was going well, mainly thanks to their excellent foreman. Then one day I saw him having an argument with the agency boss. The next day, the foreman was gone. When I asked what had happened the agency boss told me he had gone to another company. I thought nothing of it until I heard that he didn’t have a new job at all, he was unemployed.

I went round to his house and his wife opened the door. But he didn’t want to see me. I heard them having an argument. It seemed there wasn’t much more I could do, so I left. To my surprise his wife hurried after me. I didn’t like what she told me. It seemed the agency boss was paying everyone in cash. She wasn’t happy because on paydays her husband was spending too much in the bar. So she’d made him insist on getting paid via their bank account. The agency boss refused – that was what the argument had been about.

I hadn’t known that the labourers were being paid in cash. The agency boss insisted there had been a misunderstanding. He promised to offer bank payments to anyone who wanted them, and to reinstate the foreman. But I was still suspicious.

I talked to my boss about it and he contacted corporate investigations. It didn’t take long to find out that the agency was making money on the side by recycling cash for a gang of drug dealers. 

The agency boss went to prison and the company was shut down. We made sure the labourers kept their jobs. I’ll always be grateful to the foreman’s wife for having the courage to speak to me.

We take care to look out for warning signs of money laundering. Here’s one of them:

If the payment is made in cash when it’s normally made by cheque or electronically.

It was my last day at the office before our summer vacation and I had a list of things to do as long as my arm. I mailed our customers and suppliers to say I’d be away, checked all the incoming and outgoing payments that were due to be made and took a final look at our cashflow over the next fortnight.  But the list kept getting longer. By the end of the afternoon my head was spinning. All I wanted to do was get home to help my husband with the kids and the packing. Our flight was that night.

It got to about six and I was just about to switch on auto-reply when a mail came through. I cursed. Five minutes later and I would have been on my way home. It was from a customer who wanted to change the details on their payment scheduled for the following week. We’d been working with them for a long time and I knew that they’d recently been taken over by an international company. So I wasn’t surprised when I saw they wanted to make the payment from an overseas bank. 

I switched the auto-reply on so that I wouldn’t have to deal with anything else that came through, and set to work on the authorisation. There was still time to catch my train if I was quick.

I ran all the way to the station only to find the train had been delayed. I didn’t mind, at least I’d got away from the office. I found an empty bench and sat down to relax for a few minutes. Someone had left a newspaper on the seat beside me. For the first time in weeks, I found myself reading about the world outside work and family. Nothing much had changed; political scandals, crime, celebrity gossip, the usual stuff. Suddenly my eye was caught by a story about a civil war going on thousands of miles away on the other side of the world. It was happening in the country from which our supplier was sending the payment. 

I’d had no idea about the war. Like I said, keeping up with the news didn’t fit into the daily schedule. It struck me as odd that the new holding company would be doing business there. It started to worry me. I told myself I was being silly, it was the accumulated stress of work that was making me anxious. And now my train was being called.

I walked towards the platform, but my legs didn’t want to go there. My stomach didn’t feel right. I called my husband and headed back to work.

I spent the next hour online. As far as I could see, the holding company that had taken over our customer didn’t have an official presence in the country. Then I looked at the bank. My blood ran cold. Two years ago they had been accused of assisting with illegal arms deals, though no one had been prosecuted. I reversed the authorisation and called my boss.

We made the plane with two minutes to spare. My boss was great. Once I had briefed him he insisted that I go. It turned out that the holding company was not all it appeared to be. It had legitimate interests, like our customer, but these were a front for its main activities, which were drugs, people trafficking and illegal arms sales. 

If the train hadn’t been late we could have ended up supporting their crimes for months or even years to come. And when it all came out, as it nearly always does, I’d have been in big trouble. As it was, our CEO called me to his office and thanked me personally for raising the alarm.

Next year, I’m going to take a whole day off before going on holiday. 

We stay alert – and maintain controls to detect, investigate and report suspicious activity.

If at any point we have any suspicions about actual or potential money laundering activity, we report it at once. 

I felt so sorry for her. She was a new financial officer at one of our biggest customers, and she sounded like she was in tears.

‘I’m so sorry,’ she said. ‘I’ve made a terrible mistake.’

It seemed she’d overpaid us for one of our recent invoices, and by quite a lot. I knew how bad it could feel when you’re in a new job and get something badly wrong, so I said everything I could to reassure her and promised I’d return the money the next day. 

Then she told me there was a new procedure for returned overpayments. They had to be sent to a separate account to be double-checked before they were credited to the business unit in question. She apologized again and thanked me for being so kind. She sounded a bit calmer now, not in tears any more. I felt I’d done my good deed for the day.

The account details were fine. It was a different bank but it was in the company name so I couldn’t see a problem.

But then the next week it happened again! For an even larger amount. When it happened a third time I told her as gently as possible I needed to have a conversation with her boss. She said she understood perfectly, but that he was away travelling until the end of the month. 

I never heard from her again. When I spoke to her boss, he informed me she’d left the company. But he couldn’t understand the overpayment, because the invoices he had were for the right amount. Except they weren’t. They were much higher than the ones we’d submitted. 

They’d been falsified. With my heart in my mouth, I checked the bank details. What I’d missed was that ‘&’ had been substituted for ‘and’ in the company name.  Needless to say, the account had been emptied and closed.

The police interviewed me for hours before deciding I was innocent. However, there was no prospect of getting the money back, which meant I’d cost Serco more than five times my annual salary. I was fired. And with my reputation gone, I still haven’t found another job. I’m driving a taxi for the time being. Or perhaps forever. I keep thinking of that fearful voice and how it fooled me. But in the end it’s down to me – I paid the price for letting my feelings cloud my judgement. 

We take care to look out for warning signs of money laundering. Here is one of them:

If a customer asks to take payments in a form that is outside the normal terms of business.

I looked again at the invoices. They just seemed to be way over the top, even for this brand new health centre we were going to provide management and other services for. 

It wasn’t really my business, but sometimes my eye for detail just won’t let things go. My colleagues call me ‘Mrs Nitpicker’ because of it.

A few weeks earlier, my boss had been all smiles when he came back from a prestigious reception. We were starting up in a new country where we were required to have a local partner. No less a figure than the Minister of Health had introduced him to his brother who ran the partnership company. Better still, they owned premises that were perfect for us and had offered them to us at an extremely competitive price.

As part of the due diligence process I had to review their accounting system, which is how I came to be going through a batch of invoices that had nothing directly to do with us. 

The problem was, some of them were in the local language which I was still trying to learn. Most people would have ignored them, but once again my obsession for detail got the better of me. So I had the invoices translated, which is how I came to be wondering how two and two appeared to be making ten. 

My boss seemed to hit a raw nerve when he took it up with the company. When he insisted on getting to the bottom of the issue they pulled out and we were back to square one. My boss and I weren’t popular. People said we’d lost a fantastic deal by making a fuss about nothing.

But we hadn’t lost anything at all. Six months later the Minister of Health was arrested. It turned out he’d been embezzling government funds and then using the company to launder the money. Those invoices had been part of it. But so were the premises that we’d almost bought – but hadn’t. If we’d done the deal, we’d have been helping them to recycle what they’d stolen from the government – and that would have been the end of Serco’s reputation, and mine too.

People still call me Mrs Nitpicker, but they say it with respect now.

We stay alert – and maintain controls to detect, investigate and report suspicious activity.

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Bribery and corruption

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Gifts and hospitality

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Conflicts of interest

We always declare any potential conflict of interest. If we’re not sure, we ask.

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We deal fairly and honestly with suppliers, strategic partners and agents, and expect the same of them.

Trade sanctions and export controls

We take care to know and follow the rules.

Accurate records, reporting and accounting

We always maintain accurate records, reports and accounts.

Tax evasion

We never do it, or help anyone else to.

Insider trading

Never use inside information for insider trading – it’s a serious crime.