Suspicious Activity Reports (“SARs”) are a key weapon in anti-money laundering controls and it is interesting to see the large increase in SARs from the UK. I enjoyed reading this article from the team at Ropes and Gray looking into the reasons behind this.
Being able to efficiently and effectively identify and submit SARs inevitably involves data. The data is the key asset an organisation has and this needs to be dealt with appropriately. This does not start with simply analysing the data on the system, but understanding how data and information flows through an organisation, otherwise key data flows can be missed or mistranslated in normal operations.
We often get involved in projects where clients need an independent review of their systems and data (increasingly due to a potential transaction) or require an investigation into potential failings within their own systems, often driven by regulatory action. Given the strict privacy rules in certain countries this often needs to be performed in-country and often within the institutions' own infrastructure.
Data quality, data completeness and data integrity are key considerations that need to be addressed in all of these cases, otherwise you potentially end up basing your analysis on a false set of facts.
Please let me know if you’d like to learn more about our services in this area.
UK anti-money laundering (“AML”) authorities are receiving more Suspicious Activity Reports (“SARs”) than ever. The numbers of cases in which they are being asked to give clearance for transactions to proceed increased by over 50 per cent in 2018/19.