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 Improving the results from LEA use of SARs 2.6.12 We recommend a number of changes to the ways in which LEAs handle SARs in order to bring the success rate to the level of the most successful agencies and then to improve it further. In identifying recommendations to meet what we recognise are the varied and differing requirements of the range of LEAs, we have sought to ensure that they are flexible. This will allow a differing emphasis to be placed on them by different LEAs depending on their individual circumstances. We propose that: • Certain provincial Financial Investigation Units (“FIUs”) should be merged on a regional basis for the purposes of receiving and actioning SARs. • The Assets Recovery Agency Centre of Excellence should develop guidance on best practice for Financial Investigators handling SARs. Training modules for both FIU and non-FIU officers should be established, making use of the skills and experience of NCIS and other LEA training bodies. • LEAs should have access to Elmer terminals (within important access limits) to view their SAR queue, recommend SARs for development, and to enable direct searching of any SARs, although they will only be able to view the full details of intelligence only SARs. LEAs should be required to record their progress with individual SARs and provide feedback on cases directly on Elmer, making Elmer a more effective tracking mechanism for ECB. • ECB should re-negotiate LEAs’ service level agreements and report on LEA results achieved. This should be used to help ensure a greater dialogue between NCIS and LEAs on issues of joint concern regarding the processing of SARs. • The Home Office should include money laundering and the proceeds of crime issues within the relevant annual plans for LEAs and question the use of SARs in meeting LEA PoCA objectives. • The information contained within Elmer relating to successes arising from the use of SARs should be widely advertised by all stakeholders. • The successes derived from the SAR regime should be used to support and assist LEA resource allocation decisions. 2.7 Immediate next steps 2.7.1 We believe that the first priority in implementing our recommendations is the establishment of the Task Force. This body will drive and monitor the processes for taking forward the other recommendations. We would anticipate that this could be established with the right members reflecting the range of stakeholders within three months of this report. The Government commitment and backing to the SAR regime and the implementation of the recommendations in this report could be integrated with and made public at the time of the formal establishment of the Task Force. 2.7.2 Alongside the establishment of the Task Force, the Home Office work on the definition and publication of the standard form should be continued and completed. Once jo/fh/519 20
kpmg Review of the regime for handling Suspicious Activity Reports Report of recommendations KPMG LLP introduced this will help ensure that a greater proportion of SARs are reported in electronic form (even if by email with an attached document in the first instance) and therefore reduce ECB inputting time. 2.7.3 ECB should prepare a detailed plan of how it will respond to our recommendations and this should be presented at the first meeting of the Task Force. Its first task should be to act to remove the work in progress backlog and to allocate it by electronic batch transfer (after limited searches of Elmer and Alert) to individual LEAs (e.g. by cutting it to CD- Roms). The individual LEAs should then decide which (if any) SARs they wish ECB to develop into full intelligence packages based on their experience and local knowledge. The remainder should be held on Elmer as intelligence only and be available to be searched. 2.7.4 In addition to the work in progress being removed, the number of SARs processed and disseminated by the ECB should be reduced in the short-term by ECB reviewing all SARs as now but identifying only a minority for further processing and the development of an intelligence package. We recommend that, going forward, packages should be produced in much fewer cases (i.e. only for those SARs where LEAs have requested it, taking account of the recommendation of NCIS). 2.8 Timetable of key events 2.8.1 We would expect the proposed changes to structures and processes, including all the changes recommended to Elmer, to take between six and 12 months to implement. The recommendations that flow from this, including, for example, reporting on progress against the aims of the regime, may take a further 12 months to be fully in place. 2.8.2 Figure 2.2 on the following page sets out the key milestones for implementing the recommendations of this report over the next two years. jo/fh/519 21
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