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

More documents

Recommendations

Info

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
kpmg Review of the regime for handling Suspicious Activity Reports Report of recommendations KPMG LLP 9.3.10 The LU should reject and provide feedback on poor quality SARs. SARs should be rejected on the basis of inappropriate methods of submission, incomplete information or poor quality reason for suspicion. Completion Date: September 2003 Agency: ECB 9.3.11 ECB should establish a closer working relationship with the FSA and other regulators. The LU should notify persistently poor quality reporting, namely low quality, defensive or insufficient reporting, to regulators. Completion Date: Ongoing Agency: FSA and ECB 9.3.12 ECB should provide a range of information and analysis on market-wide issues to disclosing entities, regulatory bodies and relevant trade associations. This should include sanitised examples of high quality SARs and details of the volume and nature of SARs received from different sectors of disclosing entities. Completion Date: Ongoing Agency: ECB 9.3.13 The LU should use a variety of methods to provide generic feedback, for example, through the NCIS website, press releases, letters to disclosing entities, FSA and other regulators. Completion Date: Ongoing Agency: ECB 9.3.14 LEAs should be required to provide regular feedback to the LU. This feedback should include examples of high quality SARs, specific time-limited interests, generic typologies, and criteria for actioning a SAR. Completion Date: Ongoing Agency: LEAs Recommendation 14: Sectoral analysis of providers of SARs (Report section 7.5) 9.3.15 The IDU should carry out sectoral analysis of all types of providers of SARs, and the results discussed with relevant regulators and trade bodies/associations as appropriate. Completion Date: June 2004 Agency: ECB jo/fh/519 85
Page 1 and 2:
Money Laundering: Review of the Rep
Page 3 and 4:
kpmg Review of the regime for handl
Page 5:
Page 8 and 9:
Page 10 and 11:
Page 12 and 13:
Page 14 and 15:
Page 16 and 17:
Page 18 and 19:
Page 20 and 21:
Page 22 and 23:
Page 24 and 25:
kpmg Figure 2.2: Timetable of key e
Page 26 and 27:
Page 28 and 29:
Page 30 and 31:
Page 32 and 33:
Page 34 and 35:
Page 36 and 37: kpmg Review of the regime for handl
Page 102 and 103: kpmg 1. Providers of SARs submit el
show all

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

Create successful ePaper yourself

Delete template?

Save as template?