The High Court has clarified whether banks owe liability or have disclosure obligations to their customers in respect of whom they have made money laundering disclosures. This case highlighted the difficult practical issues which can arise when a bank reports money laundering suspicions in relation to a customer. The High Court firmly rejected the customers’ claim that the bank had acted improperly in refusing to follow instructions whilst awaiting consent from SOCA in respect of a SAR and also found that the bank had no obligation to provide information to the customers concerning the reasons for its refusal to act on instructions. Although the conclusion will be of comfort to banks, the case does highlight the need to ensure that banks have in place clear procedures in order to be able to withstand challenges from their customers, and suggests that firms may wish to review whether their standard terms of business provide adequate protection. Click here for our briefing on the case.