04.05.2015 Views

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

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

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

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

kpmg<br />

<strong>Review</strong> <strong>of</strong> <strong>the</strong> regime for handling Suspicious Activity Reports<br />

Report <strong>of</strong> recommendations<br />

KPMG LLP<br />

Our survey with regard to dissemination covered <strong>the</strong> success <strong>of</strong> automatic searching, <strong>the</strong><br />

necessity for manual search, <strong>the</strong> proportion <strong>of</strong> valid search results, <strong>the</strong> impact <strong>of</strong><br />

structuring intelligence and <strong>the</strong> time taken to carry out key processes.<br />

Meetings and visits<br />

Pilot phase<br />

During <strong>the</strong> pilot phase we conducted 29 meetings with interested stakeholders.<br />

Main phase<br />

During <strong>the</strong> main phase <strong>of</strong> our review in respect <strong>of</strong> Sample A visits were made to nine<br />

providers <strong>of</strong> SARs.<br />

During <strong>the</strong> main phase <strong>of</strong> our review in respect <strong>of</strong> Sample B visits were made to nine<br />

LEAs.<br />

In addition, visits and telephone calls were also made to <strong>the</strong> following :-<br />

■<br />

■<br />

■<br />

■<br />

Three FIUs understood to be affected by competing Force priorities.<br />

National Terrorist Financial Investigation Unit (“NTFIU”), at Special Branch (“SB”)<br />

New Scotland Yard.<br />

<strong>Money</strong> <strong>Laundering</strong> Investigation Team (“MLIT”), Fraud Squad, New Scotland Yard.<br />

Operation Trident, New Scotland Yard.<br />

During <strong>the</strong> main phase <strong>of</strong> our review we conducted 17 meetings with ECB staff. We also<br />

held meetings with five o<strong>the</strong>r stakeholders.<br />

Workshops<br />

Location<br />

We held a series <strong>of</strong> three workshops during March 2003 each <strong>of</strong> approximately three<br />

hours duration. They took place at KPMG’s Salisbury Square <strong>of</strong>fices in London, <strong>the</strong> Law<br />

Society and also at our Cornwall Street <strong>of</strong>fices in Birmingham.<br />

Purpose<br />

Their purpose was to discuss and enable debate from <strong>the</strong> attendees in relation to our<br />

tentative recommendations in respect <strong>of</strong> <strong>the</strong> quality <strong>of</strong> reporting by disclosing<br />

organisations, <strong>the</strong> role <strong>of</strong> ECB and <strong>the</strong> handling <strong>of</strong> SARs by <strong>the</strong> LEAs.<br />

Attendees<br />

The workshops were attended by a cross-section <strong>of</strong> individuals from <strong>the</strong> disclosing<br />

organisations, ECB and from <strong>the</strong> range <strong>of</strong> LEAs and o<strong>the</strong>r interested parties. These<br />

included <strong>the</strong> Home Office, Treasury, <strong>the</strong> Cabinet Office and <strong>the</strong> FSA. In all, 77 different<br />

people attended <strong>the</strong> workshops, with a number attending more than one.

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!