I love FIUs, you know I do. But they do vary enormously in how they interpret (or, perhaps more realistically, can persuade the holders of their government purse strings to interpret) FATF Recommendation 29 that (my emphasis) “Countries should establish a financial intelligence unit (FIU) that serves as a national centre for the receipt and analysis of: (a) suspicious transaction reports; and (b) other information relevant to money laundering, associated predicate offences and terrorist financing, and for the dissemination of the results of that analysis”.
When I talk to MLROs about what would most improve their life – apart from the instant vaporisation of all criminals, anti-AML directors and gung-ho relationship managers, not necessarily in that order – near the top of the list is “better information from the FIU”. Better feedback would allow MLROs to demonstrate to staff (including the aforementioned directors and relationship managers) that AML is working and that SARs are worth submitting, which is turn would make it easier to secure AML buy-in in the future. But I am sorry to say that many FIUs are very poor at providing such feedback. Some – most – cite lack of resources, and I do have sympathy with that. Others just like being all secret squirrel about the information, and hate sharing – big raspberries to them. But this week FinCEN, the American FIU, has really upped the ante on SAR sharing.
On 12 May 2015, FinCEN held an awards ceremony (I’m thinking red carpet, tiaras and tantrums – can’t you just see it?) at the US Treasury “to recognise law enforcement agencies who made effective use of BSA data [i.e. SARs] to obtain a successful prosecution [and] to provide concrete evidence of the value of BSA data to the financial industry”. You can read about the prize-winners here; doubtless they all thanked their parents and primary school teachers for giving them the “vision” to “complete this roller-coaster journey”. But in all seriousness, what an excellent initiative – and six handy case studies to boot.
And just to amuse you: last week I went to have my eyes checked at a well-known high street opticians. They asked my profession – I suppose to gauge how crucial my sight is, and what sort of distance accuracy I need – and I gave the usual spiel about “anti-money laundering consultant, which means that I advise people on how to spot criminal money”. I later glanced down at my file, and under “Profession”, the optician had written “Criminal stuff”. I’m expecting the police any day now.