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

kpmg
Review of the regime for handling Suspicious Activity Reports
Report of recommendations
KPMG LLP
In the course of our review we sent out questionnaires to foreign FIUs i.e. the foreign
equivalents of ECB. These included the following countries:-
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Australia
Belgium
Canada
Holland
Switzerland
USA
Purpose
The purpose of the questionnaire was to make a comparison between how the foreign
FIUs handle the receipt and dissemination of the SARs, and to ascertain the extent to
which they applied human and electronic resource in the process.
We set out below our key findings following analysis of the response to the
questionnaires:
Figure App 5.1: Method and criteria for submission
Country FIU Key findings
Switzerland MROS Institutions are required to reach a state of “justifiable”
suspicion through additional information before
disclosing
Canada FINTRAC Policies and procedures are developed which cover the
form and content of disclosures as well as the approval
process
Canada FINTRAC All institutions are required to submit SARs
electronically
Australia AUSTRAC 98% of transaction reports are submitted electronically
Holland MOT 80% of transaction reports are submitted electronically