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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
Figure 4.3: Volumes of SARs by method of disclosure in 2002
Total
Email with CSV
batch
Email with Word
attachment
MoneyWeb
Manual reporting
(post, fax etc)
64,164 28,704 6,066 292 29,102
100% 44.7% 9.4% 0.5% 45.4%
4.6.5 Timing problems from the volume of manual reporting are exacerbated by the format in
which disclosing entities produce their SARs; 23% of the disclosing entities which
responded to our general questionnaire provided hand-written rather than typed SARs.
The use of handwritten rather than typed submissions potentially further increases the
time taken to input the information and may result in a higher risk of error.
Skills and experience of inputting staff
4.6.6 The staff recruited into ECB who input SARs into Elmer are generally graduates who
want to gain an entry into NCIS, rather than specialist typing and manual inputting staff.
As a result they are more expensive than specialist clerical workers, and their
expectations of their potential role in ECB are higher than the role which they are given.
This results in frustration and high staff turnover: nine Criminal Intelligence Officers
(“CIOs”) out of 35 and four Intelligence Service Analysts (“ISAs”) out of eight left
ECB’s core processing function in the six months to February 2003. High staff turnover
means that time is spent by experienced staff training new employees, and slows down
processing times.
4.6.7 KPMG surveys as part of our research showed that of 176 paper disclosures manually
input at ECB, 56 (32%) had no errors, 115 (65%) had between one and five errors, two
(1%) had between five and ten errors, and the final three (2%) had more than ten errors as
a result of the keying in. Some CIOs now choose to check the quality of inputting after a
SAR has been searched, even though the quality of inputting should have been checked
before the search was conducted.
Elapsed time in processing SARs
4.6.8 According to our surveys at ECB the actual time taken for SARs to be processed through
ECB is on average between 45 and 62 minutes for input, checking and dissemination,
with a further average time for automatic searches of between five minutes and an hour.
The elapsed time between a trigger event, which led to the initial unusual transaction or
activity being reported within a disclosing entity, and the dispatch of the associated SAR
package to the relevant LEA is considerably greater. The results of our analysis of
elapsed time spent in processing SARs are shown below in figure 4.4 for the first half of
2002. These timings are derived from the sample we identified as being representative of
the different types of disclosing entity and method of submission, and are average
timings. The sample we selected included 11 disclosures (out of a total of 200) which
were passed through ECB to the relevant LEA within a day of being input.
4.6.9 Where SARs were submitted to ECB in the first half of 2002 it took 181 days on average
between the trigger event and the dissemination of a SAR package to an LEA. Anecdotal
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