Book contents
- Frontmatter
- Contents
- List of figures, tables and boxes
- Acknowledgements
- Foreword
- 1 Global standards, governance and the risk-based approach
- 2 The war on dirty money is mostly being lost in translation
- 3 How much do we really know about money laundering?
- 4 The obsession with defining money laundering
- 5 Money launderers and their superpowers
- 6 Global watchlists: money laundering risk indicators or something else?
- 7 Financial Intelligence Units or data black holes?
- 8 The ‘fingers crossed’ approach to money laundering prevention
- 9 Technology: the solution to all our AML/CFT problems
- 10 SARs: millions and millions of them
- 11 Information and intelligence sharing
- 12 Investigating money laundering
- 13 Prosecuting money laundering
- 14 Snatching defeat from the jaws of victory: confiscation
- 15 Countering the financing of terrorism: money laundering in reverse
- 16 National security vs the threat of money laundering
- 17 Tax avoidance vs tax evasion
- 18 Corruption: where did all the good apples go?
- 19 AML/CFT supervision or tick-list observers?
- 20 Punishing AML/CFT failures or raising government funds?
- 21 A future landscape
- Conclusion: A call to arms
- Notes
- Index
10 - SARs: millions and millions of them
Published online by Cambridge University Press: 18 January 2024
- Frontmatter
- Contents
- List of figures, tables and boxes
- Acknowledgements
- Foreword
- 1 Global standards, governance and the risk-based approach
- 2 The war on dirty money is mostly being lost in translation
- 3 How much do we really know about money laundering?
- 4 The obsession with defining money laundering
- 5 Money launderers and their superpowers
- 6 Global watchlists: money laundering risk indicators or something else?
- 7 Financial Intelligence Units or data black holes?
- 8 The ‘fingers crossed’ approach to money laundering prevention
- 9 Technology: the solution to all our AML/CFT problems
- 10 SARs: millions and millions of them
- 11 Information and intelligence sharing
- 12 Investigating money laundering
- 13 Prosecuting money laundering
- 14 Snatching defeat from the jaws of victory: confiscation
- 15 Countering the financing of terrorism: money laundering in reverse
- 16 National security vs the threat of money laundering
- 17 Tax avoidance vs tax evasion
- 18 Corruption: where did all the good apples go?
- 19 AML/CFT supervision or tick-list observers?
- 20 Punishing AML/CFT failures or raising government funds?
- 21 A future landscape
- Conclusion: A call to arms
- Notes
- Index
Summary
For want of a nail the shoe was lost.
For want of a shoe the horse was lost.
For want of a horse the rider was lost.
For want of a rider the battle was lost.
For want of a battle the kingdom was lost.
And all for the want of a horseshoe nail.
AnonEach year tens of millions of reports about dirty money are made to the police. They are regarded as either crucial information worth killing for or debris clogging up the fight against crime. We will explain the legal reason this divergence of opinion exists and take a peek into the world of intelligence. Part of this is secret, so sorry we will need to give you a blindfold. But first, Box 10.1 gives some views from the front line.
A SAR is a formal report to the designated national FIU under AML legislation. Most reports are submitted by banks but the law in some countries requires lawyers, accountants and others to submit reports. A typical report happens when a bank official observes a transaction or series of transactions that seem suspicious. There is no definition of suspicion, but the bank official will have been trained in the meaning of suspicion. So, at the beginning there is a bit of suspicion, an inkling, if you will. They will raise the suspicious circumstances of the activity with a line manager. If the line manager also thinks it is suspicious then it goes to the organisation's MLRO, who is formally responsible to the Board for making such reports. If the MLRO thinks it is suspicious too, then a report is made to the country's FIU for a fourth opinion about whether the circumstances are actually suspicious.
The Duck Theory
You can teach people to be suspicious, you really can. Most people are not naturally suspicious, but if you expose them to suspicious scenarios they will learn how to suspect. An effective way to learn is to join the police and meet the public in a series of situations where police have been called. An added frisson is that your life may depend on calling it right. This is why the police are particularly adept at handling Suspicious Reports, which is useful because this is where they end up. For the rest of us, learning suspicion in a classroom can be rather good fun.
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- The War on Dirty Money , pp. 180 - 192Publisher: Bristol University PressPrint publication year: 2023