Money Laundering: Review of the Reporting ... - Dematerialised ID

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
maximum benefit is derived by LEAs from their receipt of SARs (section 8). Section 9
summarises the recommendations and sets out a proposed timetable for implementing
them.
1.3 Appointment of KPMG
1.3.1 KPMG were appointed to review and report on the effectiveness of the regime for
handling SARs on 15 November 2002. This followed a successful application by NCIS
to the Recovered Assets Fund (“RAF”) for funding for this review.
1.3.2 We conducted a review of a pilot sample of SARs and designed a questionnaire for
completion by attendees at the National Financial Investigators Conference in November
2002. Our detailed work programme was then set out in a variation to the initial
engagement letter dated 23 January 2003 following discussion with ECB and the Project
Management Panel (“PMP”) 1 of the results of the pilot phase at its meeting in December
2002.
1.3.3 The key elements of our fieldwork prior to producing our report were agreed to be:
• Tracking a sample of 200 SARs from disclosing institutions to identify the processes
and timing from recognition of a suspicious transaction to submission of the SAR to
NCIS.
• Conducting a survey of the key work stages at ECB (input, validation and
dissemination).
• Tracking a sample of 600 SARs sent by ECB to LEAs to assess their ultimate
outcome.
• Obtaining detailed responses to questionnaires from 62 entities which provide SARs,
including the 12 which provided those identified in the initial sample of 200, and the
57 LEAs which handle them.
• Following up and validating our fieldwork through meetings and workshops.
1.4 Objectives of report
1.4.1 The invitation to tender document noted that the UK Asset Recovery Committee (“ARC”)
wished to commission “an independent review of the process used in the UK for the
handling and dissemination of STRs.” It stated that the key objective of the report was to
1 The Project Management Panel was established as a forum for KPMG to report back to
stakeholders and interested parties on the progress of our work and to allow informed discussion of
our initial and interim findings.
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