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 4.8: Rough estimated costs of the SAR regime Disclosing entities ECB LEAs Capital cost: c£60m Annual compliance cost: c£90m Annual running cost: c£6m Annual running cost: c£5m 4.8.2 Disclosing entities have both a capital cost of installing computer systems and software, and the ongoing annual compliance cost both for staff employed in AML and antiterrorist financing activities and in ongoing training of the relevant staff throughout their organisations. It is certainly the case, however, that disclosing entities would have spent a proportion of this money in any case, regardless of the SAR regime, on AML and antifraud measures. 4.8.3 The figure for ECB costs was obtained from the NCIS finance department and includes the whole of ECB, both the personnel directly involved in the processing and allocation of SARs and those who conduct ECB’s wider liaison and intelligence development work. jo/fh/519 48
kpmg Review of the regime for handling Suspicious Activity Reports Report of recommendations KPMG LLP 5 Delivery of the aims of the regime and the recommendations of this report 5.1 Summary 5.1.1 This section of our report sets out recommendations for the establishment of a small Task Force of stakeholders to deliver the aims of the regime and our recommendations (section 5.2). The Task Force should: • Comprise individuals able to carry through change when issues arise. • Conduct regular reviews of progress against measurable outcomes. • Report to Government and produce an annual, public report. • Promote the successes of the regime. 5.1.2 The Task Force should be supported by a clear Government commitment to the aims and objectives of the SAR regime (section 5.3). 5.2 Establishment of a Task Force to deliver the aims of the regime and the recommendations of this report Recommendation 1 Establishment of a Task Force 5.2.1 There are significant issues inherent in the operation of the existing SAR regime, and it is not achieving all of its aims effectively. A small Task Force of both public and private sector stakeholders (including representatives of LEAs, reporting institutions, Government, NCIS and regulators) should be established with responsibility for driving the delivery of the aims of the regime and implementation of the recommendations of this report. This body is required because the regime is facing considerable challenge and requires immediate action. The Task Force should be chaired by a senior Home Office official and report to a Government Minister. In setting up the Task Force, there should be a clear distinction between the responsibility for ownership of the aims of the regime, which is for Government, and responsibility for the delivery of those aims, which falls to the various stakeholders in the regime, whether from the public or private sector. 5.2.2 The Task Force should publish an annual report of achievements against measurable outcomes, including progress made in meeting the aims of the regime and it should be accountable for this progress. 5.2.3 It should be responsible for seeing that the recommendations of this report are implemented and thus will need to comprise individuals of sufficient authority to carry through change in their home organisations. It will also need the authority to mobilise improvements in other stakeholder organisations, as appropriate. It should be supported by a full-time secretariat. jo/fh/519 49
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