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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
5.2.4 The Task Force should be action-focused, pro-active in carrying out change and preemptive
in anticipating and dealing with issues. It should operate until the current issues
in the regime have been addressed.
5.2.5 The SAR regime, and the processes and procedures involved in it, will not be static once
these recommendations are implemented. A key role for the Task Force in addressing the
current issues of the regime will be to conduct regular reviews of the regime as a whole to
ensure that its component elements are kept up to date with emerging trends, criminal
activities and the requirement to ensure that the aims are met; this should include
periodic review of the ongoing validity and appropriateness of the aims of the regime.
Functions of the Task Force
5.2.6 In order to meet its objective of delivering measurable progress against the aims of the
regime, the Task Force should carry out the following functions:
• Produce an initial anticipated budget for the changed resources required in relation to
those recommendations which it believes should be adopted.
• Promote the successes of the SAR regime in tackling money laundering, predicate
offences and the proceeds of crime.
• Encourage greater degrees of collaboration between the different stakeholders.
• Give support and guidance to stakeholders.
• Monitor financial, human resource and Information Technology needs and
recommend changes when issues arise.
• Provide input to the UK’s overall AML strategy.
• Assess developments overseas and determine whether additional or different steps
should be taken to meet new threats or take account of advances made by overseas
regulators, FIUs and LEAs.
• The resource available at FIUs is inconsistent in different LEAs across the UK. The
Task Force’s responsibility should include undertaking research to identify the
optimal staffing level for LEAs to deal with SARs, taking both potential SAR
numbers and local considerations into account.
5.2.7 If accepted, the establishment of the Task Force should be given immediate priority, as it
will be responsible for considering our remaining recommendations and driving the
implementation of those recommendations it accepts. In doing so it will of course need to
assess the balance between achieving immediate results and the risks of introducing
change.
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