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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
for 24 of the 29. Four of the five which were identified are currently being used in money
laundering investigations.
4.7.7 36 of the 158 SARs where it is known that investigation by an LEA was completed led to
a successful outcome, with the remaining 122 identified as being intelligence only. 18 of
these were cash seizures where the relevant LEA actively used its powers when PoCA
came into force in late 2002 in relation to the intelligence obtained from the SARs dating
from the first half of 2002, which emphasises the potential benefit that can be derived
from the combination of SAR intelligence and the powers available through PoCA.
4.7.8 The variety of other successful outcomes evident from the sample (relating to an advance
fee and other fraud, excise offences, money laundering, illegal immigration and share
ramping) highlight the range of uses to which the information on SARs can be and are put
by LEAs.
Aims and focus of LEA activities
4.7.9 Responses from the 53 LEAs which replied to our survey revealed a variety of
assumptions about the aims of the SAR regime and in consequence of that a difference of
focus and attention given to the SARs which are disseminated to them. We asked LEAs
in our survey what they considered to be the main aim of the SAR regime. We received a
variety of responses and have identified the main themes from the multiple answers given
as follows:
• 14 made specific mention of intelligence.
• 32 referred to the detection and investigation of crime (or the proceeds of crime) in
general, and six of these also mentioned the detection and investigation of money
laundering.
• Six mentioned the detection and/or investigation of money laundering only.
• Two specifically mentioned the disruption of crime.
Resource levels at individual LEAs
4.7.10 The total number of staff in the 57 LEAs dealing with SARs (as recorded in response to
our questionnaire) was approximately 500, although most of these individuals will only
dedicate a relatively small proportion of their time to dealing with SARs. Some 300 of
these relate to HMC&E staff, (who HMC&E informed us, will spend an average of 15%
of their time on SARs) leaving around 200 staff spread across the other 52 LEAs. It
should be noted that these include all staff dealing with financial crime (not solely related
to offences linked to SARs), and the more focused LEAs such as the Metropolitan Police
and City of London Police who dedicate a relatively larger number of staff to
investigating SAR related potential crimes. KPMG’s calculation on the basis of the
figures provided to us is that there were 157 “effective full-time staff” at the time of our
survey earlier this year but that there was a variation in the priority attached to SARs
across LEAs.
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