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 This report should not be regarded as suitable to be used or relied on by any reader wishing to acquire any rights against KPMG LLP other than NCIS for any purpose or in any context. In consenting to the posting of the KPMG LLP report on the Home Office and NCIS web sites, KPMG LLP does not accept or assume any responsibility to any readers other than NCIS in respect of its work for NCIS, the KPMG LLP report or any opinions that KPMG LLP may have formed and, to the fullest extent permitted by law, KPMG LLP will accept no liability in respect of any such matters to readers other than NCIS. Should any readers other than NCIS choose to rely on this report, they will do so at their own risk. Copyright © KPMG LLP, the UK member firm of KPMG International, a Swiss association. July 2003. All rights reserved. KPMG Forensic This report contains 89 pages jo/fh/519
kpmg Review of the regime for handling Suspicious Activity Reports Report of recommendations KPMG LLP Contents 1 Introduction 7 1.1 Importance of the SAR regime 7 1.2 Structure of the report 7 1.3 Appointment of KPMG 8 1.4 Objectives of report 8 1.5 Uses of report 10 1.6 Sources of information 10 1.7 Caveats 11 1.8 Acknowledgements 12 2 Summary 13 2.1 The history of the regime and its aims today 13 2.2 Current successes 14 2.3 Current issues 14 2.4 Key challenges 17 2.5 Commitment to change 17 2.6 Summary of recommendations 18 2.7 Immediate next steps 20 2.8 Timetable of key events 21 3 History, aims and successes of the current SAR regime 23 3.1 Summary 23 3.2 The history of the regime 23 3.3 Recent developments 25 3.4 The aims of the SAR regime today 28 3.5 Existing successes of the SAR regime 30 4 Key issues and challenges across the SAR regime 32 4.1 Summary 32 4.2 Ownership of the SAR regime 32 4.3 Quantity of SARs and quality of reporting 33 4.4 Feedback to disclosing entities 36 4.5 Value added by ECB processes 38 4.6 Timeliness of processing SARs at ECB 41 4.7 LEA activities and use made of SARs 44 4.8 Cost of the SAR regime 47 5 Delivery of the aims of the regime and the recommendations of this report 49 5.1 Summary 49
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