An accountant working in the regulated sector suspects that a client is laundering money through a complex web of offshore shell companies. The accountant decides not to report this suspicion because they do not have concrete proof. Under the Proceeds of Crime Act 2002 (POCA), has the accountant committed an offence?

Under Section 330 of the Proceeds of Crime Act 2002, individuals working in the regulated sector (like accountants, lawyers, and bankers) commit a criminal offence if they fail to disclose to the nominated officer (MLRO) or the NCA that they know or suspect, or have reasonable grounds for knowing or suspecting, that another person is engaged in money laundering. Proof is not required; suspicion is the threshold.