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

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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
kpmg Review of the regime for handling Suspicious Activity Reports Report of recommendations KPMG LLP Appendix 3 Proposed new SAR processes
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