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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
Figure App 5. 2: FIU resources
Country FIU Key findings
USA FINCEN Inputting is outsourced and sent to a separate centre for
checking
Switzerland MROS FIU includes personnel with specific professional
experience in different fields (banking, fiduciary,
insurance, legal services, police)
Belgium CTIF/CTI Police Liaison officers are seconded to the FIU from
police forces and provide the links between the SARs
and the predicate offences
Figure App 5. 3: Dissemination
Country FIU Key findings
Switzerland MROS Separates cases for which a conclusion can be drawn as
to the criminal origin of the assets, or a connection to
organised crime. The remaining cases are forwarded to
the LEAs
Canada FINTRAC Researches current money laundering techniques and
selected indicators to identify transactions associated
with money laundering and terrorist funding activities
Belgium CTIF/CTI Cannot disseminate SARs to law enforcement
Holland MOT Cannot disseminate SARs to law enforcement
USA FINCEN Does not disseminate information
Figure App 5. 4: Information available to LEAs
Country FIU Key findings
Australia FINTRAC LEAs have general and specific access to all SARs
USA FINCEN All SARs are available to a range of LEAs
simultaneously
USA FINCEN Gateway program: Internal Revenue Service (“IRS”)/
Customs/law enforcement have access to the IRS /
Detroit Computer Centre (“DCC”) mainframe. Gateway
users may dial up and request data through FINCEN.
Requests are logged. FINCEN track the data and match
subjects and identify related cases for them