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 6 Focusing and defining the work of ECB 6.1 Summary 6.1.1 This section sets out our recommendations for changing the structure and processes of ECB. These cover: • Establishing a new management structure for ECB (section 6.2). • Establishing a new Data Management Centre (“DMC”) outside London to input and process SARs (section 6.3). • Increasing the use of electronic reporting methods (section 6.4). • Using initial automatic search and allocation processes for SARs within Elmer (section 6.5). • Establishing a new Liaison Unit (“LU”) with greater financial investigation and financial services knowledge to identify high priority SARs and recommend them to LEAs, and to liaise with both disclosing entities and LEAs (section 6.6). • Developing fewer intelligence packages for LEAs, but focusing on those most likely to generate successes (section 6.7). • Establishing an Intelligence Development Unit (“IDU”) to develop intelligence packages and conduct analysis of the Elmer database (section 6.8). • An approach to managing the backlog of work in progress SARs (section 6.9). 6.2 Structuring and strengthening the management of ECB Recommendation 3 6.2.1 As is clear from the range of issues we have identified and the scale of the task involved in implementing our recommendations, there is significant work to be conducted at ECB to ensure the more effective achievement of the aims of the SAR regime. 6.2.2 We believe that the combination of the management challenge in implementing our recommendations together with the range of existing responsibilities of ECB (see section 4.5 above), are of such magnitude and scope that the existing management structure needs to change in both depth and quality to ensure that ECB operates to its optimal performance capability. 6.2.3 Our recommended structure envisages ECB split into three core functions for processing SARs as shown below in figure 6.1. Each function would provide a distinct and valuable contribution to ECB’s role, and to the successful operation of the SAR regime as a whole. jo/fh/519 52
kpmg Review of the regime for handling Suspicious Activity Reports Report of recommendations KPMG LLP Figure 6.1: Proposed structure of ECB ECB Data Management Centre Liaison Unit Intelligence Development Unit 6.2.4 Each of these functions would require a strong management team, comprising high quality individuals to run the function with a strong assistant to support them. The three function heads should report to the Head of ECB. The position of assistant to the Head of ECB should also be filled. The overall senior management team responsible for the operational aspects of the SAR regime would therefore increase significantly from the current levels. 6.2.5 There will also be additional management required to cover ECB’s other responsibilities such as the Egmont Group and the TFT. In addition ECB senior management resource will need policy and legal support in relation to dealing with other stakeholders, addressing changes to either the law, MLRs or the Guidance Notes, and conducting risk assessment. 6.2.6 The management of the DMC should be separate from the responsibilities of the rest of ECB given that the skill set required for managing and motivating a team of primarily inputting staff and checkers of data are different from those needed to manage a group of analytical staff undertaking what can be complex and demanding assessments of potential criminality elsewhere in ECB. It will be important to ensure that the overall management team includes a diversity of experience, background and skills. Given this, the pool of potential candidates for the three functional head posts is likely to include individuals with financial services experience who are not currently involved in Government or LEA work. 6.3 Establishment, staffing and role of separate ECB Data Management Centre Recommendation 4 Establishment of a Data Management Centre 6.3.1 A separate DMC should be established as a part of ECB but located outside London. The DMC should employ new management separate from that of ECB, to which it should report. This new DMC management should be drawn largely from non-LEA backgrounds and should have experience of a clerical environment and/or undertaking inputting activities. This may include former managers of call centres and other roles focused on maintaining staff motivation within a structured and routine work programme. jo/fh/519 53
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