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