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Key definition
ACT definition

What does ACT mean? In corporate and banking practice, ACT usually refers to the Association of Corporate Treasurers, the UK-based professional body for corporate treasury professionals, rather than a statutory “Act”. It is not defined in legislation or case law; the acronym is market terminology used in transaction documents and governance materials. The Association of Corporate Treasurers promotes professional standards in liquidity management, funding, cash and risk management, foreign exchange and derivatives. It publishes guidance and a code of ethics and awards recognised qualifications (including AMCT and FCT). In legal contexts, references to “ACT-qualified” personnel or to ACT good practice may appear in treasury policies,...

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POCA 2002 Part 7 (UK): Information sharing in the regulated sector—voluntary disclosures, required notifications and joint disclosure reports (superSARs), confidentiality, good faith and ss 330–331

Practice notes
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This Practice Note outlines how the Proceeds of Crime Act 2002 (POCA 2002) addresses the sharing of information within the regulated sector and, specifically, how POCA 2002, Pt 7 (money laundering) provides for voluntary disclosures, compulsory notifications and collaborative joint disclosure submissions (often called ‘superSARs’)

These provisions should be read alongside the principal money laundering offences of:

  • concealment, arrangement or the acquisition, use or possession of criminal property (refer to Practice Notes: Money laundering offences—concealing, disguising, converting, transferring and removing; Money laundering offences—acquisition, use and possession; and Money laundering offences—the arrangement offence), respectively
  • non-disclosure of a suspicion of money laundering by a person in the regulated sector, a nominated officer within the regulated sector, or another nominated officer (refer to Practice Note: Money laundering offences—failure to disclose offences)
  • tipping off within the regulated sector and acts that prejudice an investigation which may subsequently follow a disclosure (refer to Practice Note: Money laundering offences—tipping off and prejudicing an investigation)

The provisions governing information sharing in the regulated sector deal with:

  • the legitimising of disclosures by treating statements made to a constable, customs officer or nominated officer about suspicions of money laundering as protected disclosures, and therefore ultimately not a breach...
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Michael Potts
Michael Potts

Michael is a specialist in the defence of corporate and financial crime and regulatory investigations and prosecutions. He has represented senior executives and other professionals in many high-profile domestic and international investigations and prosecutions conducted by the SFO, FCA, NCA and other prosecution/regulatory agencies.Michael regularly advises and represents senior financial services personnel facing FCA/PRA and other regulator investigations and disciplinary action. He also advises and represents high-net-worth individuals facing revenue investigations and potential prosecutions.Michael has also been extensively involved in advising clients facing financial and trade sanctions both domestically and globally with experience of sanctions regimes in a range of countries. His most recent experience includes representing high-net-worth individuals that are the subject of sanctions imposed by OFAC, OFSI and the Minister for External Relations and Financial Services (Jersey), including challenging the ‘designated’ status of a number of...

Web page updated on 21/05/2026

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