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 SARs should then be retained within Elmer as intelligence only and would be subject to the existing ongoing analysis by ECB. 6.9.7 There is the potential for further work in progress to develop in the period between this initial cut of the database and the introduction of the full suite of changes to Elmer and LEA process as set out in these recommendations. The same process should be adopted at the time the new procedures are introduced to manage any remaining work in progress. If the launch of the new procedures is delayed for whatever reason, this rough allocation should take place after six months and then again prior to launch. jo/fh/519 62
kpmg Review of the regime for handling Suspicious Activity Reports Report of recommendations KPMG LLP 7 Improving the quality of reporting of SARs 7.1 Summary 7.1.1 This section of our report sets out our recommendations to improve the quality of SARs being submitted to ECB and ensure that the right information reaches LEAs. This is divided between: • Education by ECB of stakeholders on typologies and quality issues (section 7.2). • Inclusion of mandatory fields in the standard form of disclosure, encouraging disclosing entities to alert ECB about high impact SARs and encouraging electronic reporting (section 7.3). • Increasing feedback to disclosing entities through rejection of poor quality SARs, contact with the regulators, periodic reports by ECB on the performance and outcome of SARs and on market-wide issues, and regular feedback from LEAs to ECB on individual SARs and generic typologies (section 7.4). • Analysis by ECB of providers of SARs in order to identify the weakest points in the financial system (section 7.5). 7.2 Education regarding the SAR regime Recommendation 11 Education role for ECB, trade bodies and other interested stakeholders 7.2.1 There is a clear need for improving the general level of awareness of the scope and requirements of the SAR regime across all potential providers of SARs. This would ensure that all relevant entities become familiar with their statutory obligations and the recent changes under PoCA and that they are compliant with these obligations in ways consistent with the recommendations of this report in order to reduce the amount of overand under-reporting and poor quality reporting. Appropriate liaison should take place between the different stakeholders to ensure a clear and joined up message is provided. 7.2.2 The LU should continue to provide training and seminars itself, and speakers to external training sessions and conferences on issues of current concern. In doing so it should act as the public face of ECB in actively participating in training days and seminars organised by trade associations and external training providers to emphasise both the importance of quality reporting and the role and scope of ECB to allow the maximum possible exchange of experiences and knowledge. It should also communicate areas of best practice to the external providers of training for the various financial and other industries to ensure that this is disseminated as widely as possible. 7.2.3 The various trade bodies for industries affected by the new MLRs and PoCA will also continue to play a key role in the education of their members, particularly those brought into the MLR net for the first time. The requirements of the regulators, and particularly the FSA, on the provision of training for staff are important. jo/fh/519 63
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Money Laundering: Review of the Reporting ... - Dematerialised ID

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