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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
6.5 Automatic search and initial allocation processing at the DMC for
SARs input into Elmer
Recommendation 6
Automatic initial searching of core databases
6.5.1 The DMC should conduct an automatic search for SARs after they have been input
into/transferred onto Elmer. This search should include Alert “nominals” (i.e. subject
names), the Elmer database, the PNC and CEDRIC. This search should capture a
considerable amount of information which is currently contained on local LEA databases
because there are few subjects who are on local databases who have not been convicted
of a recordable offence and are therefore not on the PNC.
6.5.2 The results of this search should not be manually verified by the DMC; only the number
of hits against the various systems will be recorded rather than their quality or relevance
to the subject.
Scoring of individual SARs
6.5.3 Each SAR should then be automatically scored on the basis of the results of the search
relative to the number of hits against the different source systems. ECB should determine
and agree the relative weights and priority to be adopted in relation to each type of system
hit, in consultation with those LEAs which are high users of SARs. This score would
then allow the identification of an initial relative priority for each SAR based on the links
identified with other SARs or intelligence obtained from other databases. The scoring
process should be regularly reviewed in consultation with LEAs to ensure they accurately
reflect the changing operational factors relating to successful and high quality SARs.
Automatic initial allocations of SARs to LEAs
6.5.4 The system should initially automatically allocate SARs to an LEA within Elmer prior to
LU review. This allocation would be based on a number of different contributory factors,
including, as now, the postcode for the relevant subject and any previous allocations. It
should also make use of the additional information arising from the searches in the
allocation of previous related hits, together with any indicative allocation or suggested
predicate offence provided with the SAR by the disclosing entity. It should take account
of any previous search requests submitted by any LEAs. It should also make use of
information from the PNC where an LEA may already have information on or an interest
in the subject of the SAR. The final component to be used should be ongoing written
information provided by the various individual LEAs of their requirements, areas of
interest and current priorities.
6.6 Establishment, staffing and role of ECB Liaison Unit
Recommendation 7
Establishment of a new ECB Liaison Unit
6.6.1 The ECB should increase its resources dedicated to improving the quality of disclosures.
It should establish an LU within ECB which will both take over the functions of the
jo/fh/519 56