Curiosity (CRS/SARs)

[wellington]

SAR's who actually receives theses?

I recognise they are linked up with AML/CRS, but i've never really understood who received SAR's, an example.

German national living in Dubai, does a transfer from a Singapore Bank to HK.

Where does the information actually go? -> I'd imagine

Filed under Individual x in Singapore, which is shared under SAR with HK, and shared under CRS with Dubai and Germany.

 

[Sols]

SAR (Suspicious Activity Report), in some places still called STR (Suspicious Transaction Reports), are reports filed by any employee of a financial institution in case of suspicious activities/transactions. They go to the company's MLRO (Money Laundering Reporting Officer) who reviews it and decides if it's severe enough to report to local law enforcement or to just store for future reference.

When an SAR is filed, it is absolutely forbidden to tell the client this as this can be used by criminals as a signal to start destroying evidence or try to learn what triggered it.

If the MLRO passes the report to law enforcement, it usually goes to the financial crimes unit of local police or separate competent authority. At that point, it's a law enforcement task.

SAR/STR are unrelated to CRS (Common Reporting Standard), which is part of AEOI (Automatic Exchange of Information). They are not included in any such exchange of information mechanisms. We're looking at MLATs (Mutual Legal Assistance Treaty) or similar interntional/cross-border law enforcement cooperation instead.

 

[wellington]

SAR (Suspicious Activity Report), in some places still called STR (Suspicious Transaction Reports), are reports filed by any employee of a financial institution in case of suspicious activities/transactions. They go to the company's MLRO (Money Laundering Reporting Officer) who reviews it and decides if it's severe enough to report to local law enforcement or to just store for future reference.

When an SAR is filed, it is absolutely forbidden to tell the client this as this can be used by criminals as a signal to start destroying evidence or try to learn what triggered it.

If the MLRO passes the report to law enforcement, it usually goes to the financial crimes unit of local police or separate competent authority. At that point, it's a law enforcement task.

Thanks, that makes perfect sense, ergo when a transaction is delayed etc, then its DD being carried out.

Still remains to be known how that works on an international scope though, i.e example above.

Seems paperwork (files) will just be building up without any actual action, which makes the entire thing pointless, unless there's a shared interconnected DB (likely be violations of various laws etc).

 

[Sols]

If a bank in Singapore finds that you do something suspicious, it goes to STRO (Suspicious Transactions Reporting Office) which is a part of the Singapore police force.

But if the bank in Singapore doesn't think what you do is suspicious, but the recipient bank in Hong Kong does, it then goes to JFIU (Joint Financial Intelligence Unit) which is a part of the Hong Kong police force.

Whether UAE or Germany gets involved depends on whether the case is interesting enough to warrant cooperation under an MLAT or something like Interpol. Generally speaking, that's rare and the bank in Hong Kong will either freeze the funds or send them back to Singapore depending on the outcome of the SAR. If you're unlucky, you'll end up having to petition a court in Hong Kong or Singapore to release your funds.

 

[wellington]

Interesting, then with so many people on here trying to hide money in overseas accounts, and under extensions of themselves (shell companies), and potentially laundering (lot of what i've read reads like that), its a wonder you don't see more cases launched against people.

I think (personally) it's a mass failing of the system, and needs re-thinking for the modern world.

 

[Sols]

Banks are over reporting, FIUs are under staffed, and cases are difficult to pursue across borders. It can take years for an SAR to render prosecution and court proceedings.

Even so, most money laundering cases are small and don't make it to the front page news. Most barely make local news. If you start scouring court records, you will find there are cases.