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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
The sample
A sample of 600 SARs was selected from a population spread across 19 LEAs. The
specific sample represented approximately 0.9% of all SARs disseminated by ECB during
the above-mentioned period.
We circulated the 19 LEAs with a specific questionnaire that sought information on the
sample of 600 SARs, including details of the ultimate uses of SARs by the LEAs.
The selection criteria
Our sample considered the highest recipients of SARs during the period and also covered
a cross-section of types of user taking account of their relative volume of SARs.
The scope of the general questionnaire
We circulated 57 LEAs with a general questionnaire, which included the 19 LEAs that
received the specific questionnaire. The questionnaires were followed up by visits to nine
LEAs where we challenged the responses provided by the LEAs.
The general questionnaire sought information on the main and subsidiary aims of a SAR,
the outcome of SARs received by the LEA, the components of a successful SAR, the
resource utilised by that LEA to deal with the SARs it receives, and what works well in
the current regime. The questionnaire focused on the process which the LEA undertook
following receipt of each of the identified SARs.
We received responses from 53 of the 57 LEAs.
ECB workstream
Objectives
Our objectives as far as the ECB workstream was concerned were as follows:
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To ascertain the elapsed time of the sample SARs from receipt to dissemination to the
LEAs.
To estimate the “real time” and resource to process a SAR through the core ECB and
understand the key factors which affect processing time and effort.
To assess different ECB processes used by the TFT and the CART, and the benefits
of secondment programmes within ECB.
The scope of the study
We designed a survey for the three key work stages of the ECB process covering input,
verification of input, and dissemination.
The scope with regard to input and verification related to the method of transmission,
format and length of a SAR. We also looked at attributes of SARs which caused delays,
error levels and which affected the time taken to input and check the information.