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 9.2.13 The LU should ensure that appropriate communication takes place between all key stakeholders in relation to improving the quality of SARs. Completion Date: Ongoing Agency: ECB 9.2.14 The LU should be divided into teams with specialist industry and product knowledge. SPOC should be established within each team for the larger institutions. Completion Date: June 2004 Agency: ECB Recommendation 8: Development of fewer intelligence packages by ECB (Report section 6.7) 9.2.15 The LU should identify on Elmer a minority of SARs which it believes merit further action by an LEA, and document on Elmer the reasons for any such recommendations. Each LEA would be able to view all SARs allocated to its Elmer queue, separated between those recommended for further action by the LU and those which the LU believes should be retained for intelligence only on Elmer. Completion Date: September 2003 Agency: ECB Recommendation 9: Establishment, staffing and role of Intelligence Development Unit (Report section 6.8) 9.2.16 ECB should establish an IDU which will take over the functions of the existing Intelligence Development staff and adopt a number of additional specific analytical responsibilities. 9.2.17 The IDU should include sufficient staff with appropriate analytical training and experience. 9.2.18 The IDU should process and disseminate only the minority of SARs which LEAs indicate on Elmer they wish to be developed. The development of these SARs should include verifying the results of the automatic search, searching any additional databases requested by the LEA and producing a user-friendly package disseminated to the LEAs via Elmer. Completion Date: December 2003 Agency: ECB 9.2.19 The IDU should be responsible for conducting wider strategic and tactical analysis of the information within Elmer, either at the request of others or through internal analysis of trends and typologies. Completion Date: June 2004 Agency: ECB jo/fh/519 82
kpmg Review of the regime for handling Suspicious Activity Reports Report of recommendations KPMG LLP 9.2.20 In order for the IDU to operate effectively as an analysis unit appropriate information would need to be received from both the providers of SARs and the LEAs. Completion Date: June 2004 Agency: ECB Recommendation 10: Proactive management of the backlog of work in progress (Report section 6.9) 9.2.21 The current work in progress should be proactively managed by providing LEAs their SARs directly, allocated by postcode and subject to limited unvalidated searches. LEAs would then determine which SARs, if any, should be developed by ECB. This process would be run on a regular basis until the new procedures are fully introduced. Completion Date: September 2003 Agency: ECB and LEAs 9.3 Improving the quality of reporting of SARs Recommendation 11: Education regarding the SAR regime (Report section 7.2) 9.3.1 The LU should be responsible for education in relation to the SAR regime, including the communication of typologies and methodologies to industry; annual reviews of the quality of submissions by selected providers; establishing a closer working relationship with the FSA; and the provision of training and seminars. Completion Date: Ongoing Agency: ECB and regulators 9.3.2 LEAs should also have a role in training and education to ensure their needs and requirements are identified and publicised to disclosing entities. Completion Date: Ongoing Agency: LEAs 9.3.3 The ECB section of the NCIS website should be developed to allow public access to as much non-sensitive information as possible. Completion Date: Ongoing Agency: ECB 9.3.4 Government and other stakeholders should make clear public statements to emphasise the importance of providing high quality SARs. Completion Date: Ongoing Agency: Task Force jo/fh/519 83
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