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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
9.3.5 Regulators should make public statements that their primary interest in AML controls is
poor processes, systems and controls, rather than poor judgement.
Completion Date: Ongoing
Agency: FSA and HMC&E
Recommendation 12: Standardisation of reporting processes (Report section 7.3)
9.3.6 The standard form of reporting should include core mandatory fields with additional
sector and industry specific forms as appropriate. ECB should document clear guidance
for the completion of the standard form.
Completion Date: September 2003
Agency: Home Office and ECB
9.3.7 Disclosing entities should distinguish between fast-track (those requiring pre-emptive
action), high impact (those which meet appropriate typology and quality criteria) and
standard disclosures. Disclosing entities should also indicate on the standard form
whether the SAR relates to a suspicion of fraud or is otherwise “unlikely to merit
investigation by an LEA”.
Completion Date: September 2003
Agency: Providers of SARs
Recommendation 13: Feedback to be provided to disclosing entities (Report section
7.4)
9.3.8 ECB, LEAs, the FSA, other regulators and trade bodies should work in partnership to
provide greater levels of feedback to disclosing entities and other interested stakeholders,
such as regulators and trade bodies/associations. This should include annual reviews of
individual institutions' disclosures, rejection of poor quality SARs, feedback to regulators
on quality issues and market-wide generic feedback.
Completion Date: June 2004
Agency: ECB
9.3.9 The LU should be responsible for providing specific feedback on an annual basis to
disclosing entities, detailing the use made of SARs submitted.
Completion Date: December 2004
Agency: ECB
jo/fh/519 84