Security Operations Team — Asset Recoveries
This circular aims to clarify the end to end process of cash recoveries, from seizure through to
the accounting aspect. Associated is a flowchart outlining the cash recovery process, with
further information as follows.
Recovery Of Cash
Cash is often good evidence of acquisitive crime and correct processes should be followed
where cash is discovered during an Investigation. In all cases when cash is recovered (except
POCA Cash Seizure cases) it must be counted and a record made of the amount and
denomination on either the GSO05D ‘Record of Property Seized During a Search’ or within an
Official Notebook. In addition any recovered cash which is not required in its original state as
evidence, or required for forensic analysis, or returned to the rightful owner; must be paid into an
interest bearing account for the duration of the investigation and criminal proceedings. (If cash is
retained and the reason for retention lapses then it should be paid into the account as soon as
practicable). The Post Office Ltd Security Team operates a Bank Of Ireland Recovery account
which should be used for this purpose.
Suspect Fully Cooperating with Investigation.
If cash is discovered and the suspect admits at any time that it is either stolen money or directly
or indirectly the proceeds of the crime that you are investigating, then as well as recovering the
cash as evidence the following actions should be undertaken;
1. The suspect should be asked to disclaim the property and informed that this property will
be accepted without prejudice to any action which Royal Mail Group Ltd may be advised
to take.
2. They should then be asked to complete a GS026 Disclaimer of Recovered Property.
3. A copy of the GS026 should be provided to the suspect as soon as practicable with a
further copy being enclosed in Appendix C of the case file. The original should be
retained by the Investigator until proceedings have been concluded.
Additionally, if prior to interview or further interview, the circumstances of the
recovery/disclaimer should be detailed on the tape recorded interview. If after interview, the
circumstances of the recovery should be detailed in the Investigator’s Official Notebook.
Suspect Not Fully Cooperating with the Investigation.
If cash is discovered and the suspect is not fully cooperating with the investigation, Security
Operations Managers must consider if the cash is either evidence of the offence under
investigation (this includes Money Laundering offences) or obtained as a consequence of the
offence and if so do they believe they are likely to be able to prove the case to the satisfaction of
a Court. If it is considered so and the Security Operations Manager believes that it is necessary
to recover the cash to prevent it being concealed, lost, disposed of or destroyed then it should be
recovered. Should the suspect refuse to allow the cash to be recovered then assistance of the
Police should be requested as they have a power of seizure.
POCA 2002 Cash Seizure. If an Investigator discovers an amount of ‘cash’ of £1,000 or over in
value which they think may be the benefit from crime, but do not think it is related to the case
currently under investigation, then consideration must be given to arranging a cash seizure under
POCA 2002. Under POCA 2002 Accredited Financial Investigators (AFI), Constables and
Customs Officers have a power to seize cash of £1,000 or over, if they have reasonable grounds
for suspecting that the cash has been obtained through unlawful conduct, or is intended, by any
person, for use in unlawful conduct. Accordingly if such a situation is anticipated or occurs,
contact in the first instance should be made with an AFI. If an AFI is not contactable then the
local Police should be contacted in order that they can give consideration to conducting such a
seizure. If part of a cash amount is suspected of relating to the case under investigation, then
the Police must be informed accordingly, as this part should be seized under PACE, not POCA.
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(preventing the possibility of its forfeiture being divided as per the incentivisation scheme,
whereby only half is allocated to the appropriate Law Enforcement Agency).
Bank Of Ireland (BOI) Account
The BO! paying in book (consisting of counterfoils and paying in slips) enable cash deposits to be
made at any Post Office branch. It is the Security Operations Managers responsibility to retain
the paying in book securely and to ensure that all deposits are receipted correctly by way of date-
stamped counterfoil and Horizon slip evidencing deposit. All Horizon slips are to be securely
stapled to their respective counterfoil.
Paying in books must be returned, to Post Office Security when all slips are exhausted, in order
that reconciliation can be undertaken. New paying in books should be obtained from Post Office
Security.
It is important that the following process is adhered to when a deposit is made:
1. All paying in documentation to be completed in full and counterfoil stamped to evidence
receipt (either of cash proper or cheque envelope)
2. Counterfoil and Horizon receipts to be retained, by Investigator, within paying in book
pending exhaustion and return of book or annual reconciliation of the book proper
3. Funding Notification (copy associated with circular) to be completed in full and emailed
to Post Office Security, with a hard copy placed within Appendix C of the case papers.
This should be done within 48 hours of deposit
Importantly, the Investigator also has a requirement to comment on the Funding Notification
whether ownership of the moneys lodged have been willingly surrendered / relinquished by the
suspected offender or not.
The rationale behind this account (in addition to provide an account accessible within our own
estate into which we can deposit all recoveries) has been to provide an interest bearing account
(a POCA requirement) in which to lodge moneys where ownership may be / is being disputed
pending adjudication by the Courts.
NB: Cheque deposits should be made by completing a paying in slip and associated cheques all
sealed within a BOI envelope (again to be supplied separately). The envelope will be receipted
by date stamped counterfoil and Horizon receipt that in effect confirms receipt of envelope only.
NB: BACS payments can also be made into the account. The Funding Notification should be
amended in such a way as to reflect this method of deposit.
Supporting Documents
[=I
Funding Notification
Aug11.doc
EH
Cash Seizure CIT
. . Collections Process. di
Cash Seizure CIT Collections Process:
Funding Notification:
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Post Office® Ltd Security Operations Cash Seizure Process
Have you found cash on a search at external
premises /on a suspect.
Yes No
y x
Do you suspect that part or all of the Do you suspect that the
cash relates to the crime that you are No I. cash relates to untavitul No >I No further Action Required
investigating ‘conduct
Yes Yes
vy y
Liaise with AFI / Police as the
cash may be subject to a “cash
seizure" or “detained cash"
investigation under POCA 2002
Legistation
‘Seize cash under PACE and follo
‘standard disposal instructions
‘Standard Disposal Instructions
‘Choose as appropriate
(see notes below)
_ ¥
Dispos:
posal method
Pay cash into POL Investigation
‘Team Recovery Account at any Disposal method2
Post Office® and funding Arrange for collection of cash by CVIT
notification e-mail to be sent to (Gee cash seizure CIT collection process
Post Office® Security document link on previous page)
NOTES
4/ - There is no minimum or maximum amount of cash that can be seized under PACE legislation (.2.
cash seized as evidence of the crime under investigation ), but from a H&S perspective, common sense
shoul be applied when transporting cash, any queries should be directed to your Line Manager.
2! -Cash seized under PACE should be deposited ASAP.
3/--If collecting money from a Subpostmaster — arrange to meet at a post office where the money can
be secured or paid in.
4/ -If transporting cash retain money in the boot ete
5) -If cash recovery is made following an audit where the office is going to transfer and we have
Control of the safe and alarms leave the money in the safe
6/ - Consider storing at Supply Chain sites i they are within a sensible distance
7/ - Consider police stations, safes, etc