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 9.3.16 The analysis and conclusions of these discussions should be provided to the Task Force so it can periodically assess the nature of measures in place for encouraging compliance with the SAR regime. Completion Date: September 2004 Agency: Task Force 9.4 Improving the results from LEA use of SARs Recommendation 15: Merging of FIUs on a regional basis (Report section 8.2) 9.4.1 Individual LEAs which do not have extensive resources and expertise should be encouraged to investigate the possibility of merging their FIUs to ensure that there is appropriate skilled and experienced resource to handle the receipt, assessment and investigation of high quality SARs. Completion Date: March 2004 Agency: LEAs Recommendation 16: Use of ARA Centre of Excellence to develop guidance and training on use of SARs (Report section 8.3) 9.4.2 The ARA Centre of Excellence should issue national guidelines to ensure that the benefits from the identification and provision of high quality SARs are promulgated within the law enforcement community and that FIs are trained accordingly. Completion Date: December 2003 Agency: ARA 9.4.3 Best practice information and methodologies should be used as part of the training modules which is provided for all entrants to law enforcement. Completion Date: June 2004 Agency: ACPO and LEAs Recommendation 17: LEA access to and use of Elmer terminals (Report section 8.4) 9.4.4 All FIUs should have an Elmer terminal, and all accredited FIs should have access rights to use the terminal in order to manage the SARs allocated to them on Elmer, and to conduct specific searches of all SARs on the Elmer database. Completion Date: September 2003 Agency: ECB and LEAs jo/fh/519 86
kpmg Review of the regime for handling Suspicious Activity Reports Report of recommendations KPMG LLP 9.4.5 Access protocols should be agreed between ECB and the LEAs to ensure that LEA direct access to Elmer meets the requirements of the DPA. Completion Date: September 2003 Agency: ECB and LEAs 9.4.6 Individual FIs within FIUs should manage their SAR queue and document their actions on Elmer. LEAs should review the SARs allocated to their queue in order to record decisions on Elmer about which SARs should be actioned, and which should be retained in Elmer as intelligence only. Where LEA decisions differ to LU recommendations the reasons for these decisions should be documented. Completion Date: December 2003 Agency: LEAs 9.4.7 LEAs should manage and record the status of all SARs in their queue, each SAR being identified as either open (where further work will be carried out on an SAR by the LEA), intelligence only, or complete (following the conclusion of an investigation). Completion Date: December 2003 Agency: LEAs 9.4.8 LEAs should be responsible for identifying any SARs incorrectly allocated to them and notifying the LU via Elmer of the requirement to reallocate to a more appropriate LEA. Completion Date: December 2003 Agency: LEAs 9.4.9 Where an LEA indicates that an SAR is open it should be responsible for directly updating Elmer with feedback on the status of that SAR at regular quarterly intervals, and also on completion. Completion Date: December 2003 Agency: LEAs 9.4.10 LEAs should be able to conduct specific searches of Elmer, subject to access protocols, which will allow access to all information on intelligence only SARs, but not the full details of SARs marked as open by another LEA, subject to agreements between LEAs. Completion Date: December 2003 Agency: LEAs jo/fh/519 87
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