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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
Recommendation 4: Establishment, staffing and role of separate ECB Data
Management Centre (Report section 6.3)
9.2.2 A separate DMC should be established outside London under new management with
clerical environment expertise.
Completion Date: March 2004
Agency: ECB
9.2.3 Inputting staff should be experienced clerical officers, including copy typists, with
flexible working packages.
Completion Date: March 2004
Agency: ECB
9.2.4 The DMC should take responsibility for the receipt of all SARs, the accurate and timely
input of manual SARs, the rejection of any SARs with administrative errors, the transfer
of all time-critical SARs to the LU. The DMC should file fraud disclosures (identified by
the providers of SARs on the standard forms) as intelligence only.
Completion Date: March 2004
Agency: ECB
Recommendation 5: Increase in provision of electronic reporting of SARs (Report
section 6.4)
9.2.5 Electronic submission of SARs should be made mandatory for all regulated entities
through the standard reporting format (subject to exemption criteria), and actively
promoted by the LU and relevant trade bodies to other entities, particularly those
submitting higher volumes of SARs.
Completion Date: September 2003
Agency: Home Office and ECB
Recommendation 6: Automatic search and initial allocation processing at the DMC
for SARs input into Elmer (Report section 6.5)
9.2.6 The DMC should conduct an automatic search for all non-fraud SARs against Alert
nominals, Elmer, PNC and CEDRIC. The results of the search should not be manually
verified.
Completion Date: December 2003
Agency: ECB
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