It is a defense to the substantive money laundering offenses if the relevant person intended to make an authorized disclosure but had a reasonable excuse for not doing so. The scope of the reasonable excuse defense, however, is not defined in POCA and has not been considered by the courts. For more on authorized disclosures, see the Defense: Consent topic in the Anti-Laundering – UK section.
For persons in the regulated sector who are not nominated officers, it is also a defense that they did not receive appropriate training. For further details on anti-money laundering training requirements, see here.