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Home > Banknotes > Compliance, whistleblowing and the Note Circulation Scheme

Compliance, whistleblowing and the Note Circulation Scheme

​It is important that we mitigate any risks from outsourcing cash distribution to Note Circulation Scheme (NCS) members. The main risks come from:

  • NCS members having control of notes owned by the Bank of England
  • transporting notes to and from our cash centres.

Other risks include notes being stolen and an NCS member misreporting (over-declaring) banknotes held in bond or in the note recirculation facility.

NCS members have a contractual obligation to operate within the NCS rules. We monitor their performance through compliance and security visits. We also conduct regular reviews and analysis of NCS members’ reporting and operating procedures, and members must commission an annual audit by professional external auditors.

We may also require NCS members to have in place financial guarantees which allow us to immediately recoup any losses (e.g. from a theft).

NCS members must also have liability insurance, on which we are co-insured (allowing us to make a direct claim if we need to) and the first loss payee. Furthermore, certain NCS exposures to the Bank are collateralised (i.e. the NCS member provides security to us in the form of a claim on other assets).

These measures help limit the financial risks to the public purse, and ultimately the taxpayer, while making sure note distribution, sorting and storage is efficient.

Whistleblowing and the Note Circulation Scheme

You are a whistleblower if you're a worker and you report certain types of wrongdoing. The Bank of England is a ‘prescribed person’, which means that you can make a whistleblowing disclosure about the Note Circulation Scheme to us instead of your employer. This is generally referred to as ‘making a disclosure in the public interest’.

You can make a disclosure that is protected by law about the following:

  • someone’s health and safety is in danger
  • risk or actual damage to the environment
  • a criminal offence
  • a miscarriage of justice
  • the company is not obeying the law and/or
  • you believe that someone is covering up wrongdoing.

We encourage workers, particularly those who work at members of the Note Circulation Scheme, to first use the whistleblowing procedures available in their workplace. If such procedures do not exist or if you do not feel able to use them, you can contact us on 020 3461 8703 during office hours. Alternatively, you can email us at or write to:

Bank of England
20 Moorgate
London EC2R 6DA

Disclosures made to us will be handled by dedicated whistleblowing staff at our Prudential Regulation Authority (PRA).