In a training session earlier this week, we had some lively discussions around the reporting of attempted crime – attempted fraud, attempted money laundering, attempted tax evasion. Is a SAR suitable or not, we debated, given that SARs (and their cousins, disclosures) are designed for reporting suspected laundering of the proceeds of crime, and if the crime is only attempted (rather than successful) there are no proceeds, ergo no laundering, ergo no SAR. (Great word, ergo.) The conclusion we reached is that MLROs would probably like to receive reports of attempted crime, and that they would rather receive a SAR than nothing, even if it’s not quite the right format. And actually I know plenty of MLROs who instruct their staff to report even attempted money laundering through the SAR route as a matter of course, being of the view that SARs are for reporting money laundering at any stage – whether attempted or successful, future, past or current.
And this reminded me of something I was told years ago by the FIU of a small jurisdiction. They said that they liked to receive disclosures about attempted crime (particularly money laundering, but they were happy with fraud too) as it meant that they could warn others in their jurisdiction about the attempt. They called them “round robin warnings”. This term was familiar to me: when I was a student I had a holiday job in C&A (I can imagine how envious you are: the bilious grey uniform was 100% polyester, and we got static shocks from the metal on the tills), and we used a similar system. If we spotted a shoplifter lurking on the premises, we would call our contact at M&S and warn them (“Look out for a tall chap in jeans and a blue bomber jacket, Afro hairdo and Doc Martens [be fair: this was the 1980s] – he’s pilfering from ladies’ evening-wear”); they would then call Woolies, who would call Bentalls – and so on until all the major shops in town were alerted. And the FIU said that they did something rather like this, to warn local financial services firms about a particular approach or story that was doing the rounds. I wonder whether it still happens and, if not, why not.