Predicate Offence
A predicate offence is the underlying criminal activity that generates the proceeds laundered through a money laundering offence. Under POCA, almost any criminal offence — committed in the UK or overseas — that produces a financial benefit can be a predicate offence. Common examples include tax evasion, fraud, drug trafficking, corruption, theft, and modern slavery.
an accountant does not need to identify or prove the specific predicate offence to report a suspicion. Knowing or suspecting that funds derive from criminal conduct is enough to trigger the SAR obligation under POCA s.330 — even if the underlying offence is unclear.
How different roles use Predicate Offence
A good definition should change the next action for the person reading it.
Partner or director
Check whether this term affects acceptance risk, fee scope, supervision exposure, or sign-off responsibility.
ContinueMLRO or compliance lead
Map the term to evidence, escalation, monitoring, training, and inspection readiness.
ContinueClient-facing team member
Use the plain-English explanation to ask better client questions and write clearer file notes.
ContinueOther terms that go with Predicate Offence
Money laundering is the process of disguising the proceeds of crime so they appear to come from a legitimate source. Under the Proceeds of Crime Act 2002 (POCA), the principal money laundering offences are concealing criminal property (s.327), entering into arrangements that facilitate it (s.328), and acquiring, using, or possessing criminal property (s.329). All three carry maximum penalties of 14 years' imprisonment.
A Suspicious Activity Report is a formal disclosure made to the National Crime Agency (NCA) when a person in a regulated sector knows or suspects that someone is engaged in money laundering or terrorist financing. Filing a SAR provides a defence against money laundering offences. Failure to file when there is grounds to do so is itself a criminal offence.
Before you treat Predicate Offence as handled
- Confirm which regulation, policy, or internal procedure the term maps to.
- Document the decision or evidence trail in the client file, not only in email or chat.
- Escalate where the term indicates higher risk, sanctions exposure, PEP status, suspicion, or missing evidence.
- Keep the wording consistent across onboarding, review notes, training material, and inspection packs.
Put Predicate Offence into practice with Certivus
Knowing the term is the first step. Certivus gives you the workflows — client intake, CDD, EDD, PEP and sanctions screening, audit-ready records — to apply it across every client.
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