30.This section is based on section 18A of the PTA and has the same effect. It requires banks and other businesses to report any suspicion they may have that someone is laundering terrorist money or committing any of the other terrorist property offences in sections 15–18. Subsection (1)(b) ensures the offence is focused on suspicions which arise at work. Subsection (5) preserves the exemption in respect of legal advisers’ privileged material.
31.Suspicions arising in home life were covered by section 18 of the PTA which the Government has decided, following Lord Lloyd, not to replicate.
Commentary Part Iii: Terrorist Property Section 19: Disclosure of information: duty