A new client gives payslips showing £5,500 a month, but his bank statements show regular salary credits of £3,200 from the same employer. He says: 'The payslips are right, just put them in.' What should the adviser do?
A large mismatch between payslips and bank credits is a red flag for falsified documents. The adviser must not submit misleading information (Principle 1 integrity; Fraud Act 2006) and, where there is knowledge or suspicion of money laundering, must report to the nominated officer under the firm's procedures (an offence under POCA 2002 s330 if not done in the regulated sector; a disclosure is protected by s338) without tipping off the client (s333A). Averaging figures or asking for 'different' statements would help mislead the lender.
Smoothing over inconsistent evidence rather than treating it as suspicious.
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