April 2006

Suspicious Activity Reports point investigators in the right direction

Adriana Juric of the AMLP forum and Stephen SmithKirsten Siddall of the Serious Organised Crime Agency (SOCA) delivered a very interesting presentation at the Anti-Money Laundering Professionals (AMLP) Forum's first seminar of 2006. The seminar was chaired by Adriana Juric of the AMLP Forum, featured here talking to Stephen Smith, the Managing Director of UK Training (Worldwide) Limited. Kirsten delivered with great passion the role that SOCA will be playing in its fight against organised crime and terrorist funding.

She highlighted that one of SOCA's main functions will be to gather, store, analyse and disseminate information to the law enforcement agencies, the role that was performed by the National Criminal Intelligence Service (NCIS). SOCA under the leadership of Sir Stephen Lander, formerly the Director General of MI5, has been carrying out a review of the successes and failures of NCIS's role and intends to build upon the successes of the reporting of suspicious activities. Kirsten explained that SOCA will be focussing extensive resources on the intelligent interrogation of Suspicious Activity Reports (SARs) because there is no doubt this provides clear direction on how the law enforcement agencies should conduct their investigations.

The following examples appear on www.soca.gov.uk illustrating the value of SARs.

  • A single SAR identified hundreds of thousands of pounds of serious fraud and indicated that the criminal property was being laundered.
  • A five figure cash sum was identified as the realisable assets of drug trafficking as a result of a SAR.
  • Two arrests and substantial quantities of drugs were seized as a result of a drug trafficking investigation which was given direction by a SAR.
  • A five figure cash seizure resulted from a SAR which alerted the law enforcement agencies to the latest intentions of an individual previously suspected of money laundering.
  • A number of SAR's enabled the law enforcement agencies to link a person responsible for suspicious cash placement into a wider criminal network, it was reported that without the SARs it would not have been possible to take the investigation further.

The value that the law enforcement agencies put on SARs was clear. During a question and answer session Andrew Sladen of the Metropolitan Police, Jeremy Rawlins of the Crown Prosecution Service and Tim Harvey of the City of London Police supported the views of Kirsten. They endorsed fully the SARs regime and assured the audience that a Suspicious Activity Report would not be reproduced as evidence in court. They want the originators of these disclosures not to feel that they run the risk of being identified by defendants.

The AMLP Forum aims to be the leading international forum for anti-money laundering and counter terrorist financing professionals. Visit www.amlpforum.com to find out more.

The Proceeds of Crime Act 2002 and the Money Laundering Regulations 2003 introduced legislation that affects everybody. It is important that you recognise fully how you could be prosecuted for an offence under this legislation. To find out more you should read Stephen Smith's article
Anti-Money Laundering Legislation does affect you
and the supplement to it.

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