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

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Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
meeting the specified access and usage protocols). Indirect searches of the Alert system
could also be requested via the FIU, although these would need to be conducted through
the NCIS regional offices (as is currently the case) to ensure that the confidentiality of the
Alert scheme is maintained.
8.4.19 Some LEAs (e.g. the Metropolitan Police Service) have identified that they achieve
successful results from using the information contained in SARs having transferred the
SAR data onto a local intelligence database. We believe that there are LEAs where this is
appropriate and that the feasibility and costs of doing it within the new procedures should
be explored in developing implementation plans. Where this does take place however,
the LEA would still need to meet all our other recommendations including, in particular,
updating Elmer on the progress of all SARs allocated to them through their Elmer queue.
8.5 Monitoring LEA results and establishment of new service level
agreements
Recommendation 18
Establishment of new SLAs between ECB and LEAs
8.5.1 New SLAs should be established between ECB and each of the LEAs to document their
various responsibilities under the new structure and approach. These should include
indicative timings for the provision of information between each party (e.g. ECB will
ensure that new SARs are added to Elmer within XX days of receipt from a disclosing
entity, LEAs will provide an initial indication of the status of all SARs on their queue
within YY days of receipt and commit to update this information on a rolling monthly
basis).
ECB monitoring and reporting of LEA results
8.5.2 In order to ensure that the appropriate information is input onto Elmer in a timely fashion,
and to ensure that individual LEAs are meeting their commitments under their SLAs with
ECB, ECB should monitor the results achieved by each LEA through their regular
updates of information on Elmer. It should use the results of this monitoring to provide
feedback on a quarterly basis to each LEA. This will ensure that there is an ongoing
dialogue between ECB and the individual LEAs on the areas of concern that each has in
the operation of ECB’s processes for SARs and the LEA’s use of the information
contained therein in investigating and disrupting criminal activity. This monitoring
should cover at the least:
• The numbers of SARs which are allocated, developed, which are otherwise open and
those which have been marked as intelligence only, and information on the time taken
from receipt to progression.
• The timeliness of LEA updates of the status and progress of individual SARs.
• The timeliness and content of feedback provided by LEAs on the outcomes of
successful use of SARs in investigations, prosecutions and asset recovery.
8.5.3 The results of this monitoring should be made available to the Task Force on a half-yearly
basis to allow it to achieve its objective of assessing the success of the SAR regime as a
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