Your correspondent Richard Greenwood should not be alarmed (see [2004] Gazette, 19 February, 17).
His knowledge that a local public house trades after hours in breach of section 59 of the Licensing Act is not a worry but an opportunity.
This information did not come to Mr Greenwood in the course of relevant business, so he is not obliged to notify his money laundering reporting officers.
Furthermore, every after-hours customer of the public house risks committing a money laundering offence under section 328 of the Proceeds of Crime Act 2002 when they facilitate the acquisition of criminal property by the landlord as they pay for their illegally purchased drinks.
Prosecution can be avoided by each of them making an authorised disclosure to the National Criminal Intelligence Service.
They would benefit from Mr Greenwood's advice and assistance in this connection.
I suggest Mr Greenwood should loiter outside the public house after statutory closing time, offering his services to customers as they leave - making it clear, of course, to which profession he belongs.
David Winch, director, Accounting Evidence, Manchester
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