In a recent update – Scheme Abuse and Fraud (30th September 2015) – I asked you to be on guard for mortgage fraud and explained why you should be vigilant to being used as a conduit for this type of financial crime and the steps you can take to protect yourself and your business.

It is important to understand that each adviser has a regulatory responsibility to prevent financial crime and the regulator itself is responsible for enforcement of the laws. Further details on the FCA website: https://www.the-fca.org.uk/financial-crime

By taking the practical steps referred to in the earlier update, on a consistent basis, you will be very unlikely to be exposed to fraudulent applications. Fraudsters and criminals tend to ‘prey’ on firms with a poor attitude and weak controls. That said, there is always the possibility that it could happen and it could be you that is the target. It is thought that around 1 in every 100 applications will be subject to some form of criminal intent. For many that will mean the possibility of at least one transaction each year being fraudulent.

And if it happens once, and the fraud is successful, it will probably happen again, and again. You will become an unwitting conduit for organised criminals.

It is important therefore that the Network has a system for referrals of any suspicious activity and as such I would draw you attention to the Suspicious Activity Reporting Process.

If, at any time, you become suspicious of a client or transaction, you must report your suspicions to the Right Mortgage and Protection Network Financial Crime Officer, presently myself. You will complete a ‘Suspicious Activity Report’ (SAR) form and email this for urgent attention. You will then benefit from an independent analysis of your suspicions.

In most instances it is likely that you will be advised to proceed with caution, however, where appropriate, the matter will be referred to the National Crime Agency.

Please refer to the Suspicious Activity Reporting Process to be familiar with the requirements, which is available on the Right Adviser site, within the document library under ‘suspicious activity reporting’

If you are unsure whether a SAR is necessary then feel free to speak to a member of the file review team or your compliance manager, who will be happy to offer guidance.