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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
Key dependencies for the IDU to operate effectively
6.8.10 In order for the IDU to operate as an effective analysis unit, the IDU staff and those
working in the LU should be working more closely together to maximise the benefits of
each others’ work and experience. In addition, various other elements of our
recommendations would also need to have been implemented.
• The disclosing entities would have to have provided appropriate information.
• The LEAs would have to have provided the appropriate information on an ongoing
basis to Elmer to allow proper searching and analysis of the database.
6.9 Proactive management of the backlog of work in progress
6.9.1 A key challenge for ECB is how to deal with the c58,000 SARs which remain work in
progress in a cost-effective manner with due consideration of the risks involved and an
assessment of the benefit to be gained.
6.9.2 One potential solution would be to draw a line under the existing list of SARs and merely
input them onto Elmer to be available for searching at a later date. This would, however,
run the significant risk of missing potential quality information for LEAs.
6.9.3 Another alternative would be to dedicate a team at ECB to attempt to reduce all the work
in progress using current processes. This would however be costly, distract ECB staff
from implementing the range of our other recommendations and would involve
developing a significant number of intelligence packages which would not be useful for
LEAs given the existing quality issues. In any case, ECB do not currently have sufficient
staff to dedicate to this.
Recommendation 10
6.9.4 All SARs held as work in progress at a given date (for example 30 May 2003) should be
batch transferred through the existing automatic function in Elmer. In order to save time
and resource the accuracy of the input and format of these SARs should not be checked
prior to conducting this search. The search should be restricted to the existing Elmer
database and a search against the Alert nominals to identify any flagged subjects.
Potential hits on flagged subjects should be highlighted within Elmer to allow
investigation and action by ECB. There would be no manual validation where there were
no Alert hits.
6.9.5 Details of the individual SARs and the results of the searches should then be sent to the
individual LEAs based on the postcode of the main subject. This information can be sent
out by ECB either by CSV or on a CD.
6.9.6 It should then be the responsibility of the individual LEA to determine what further action
they wish to be taken for their SARs. The initial expectation is that this would be done
following a review of the reason for suspicion, the transaction details and the unvalidated
search results against their local knowledge. LEAs can request that an intelligence
package is developed for any individual SARs which they determine are potentially “high
impact” (i.e. likely to achieve a disruption, confiscation or prosecution). Any remaining
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