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

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.
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