Double-duty SARs

Ever since some hunter in ancient times pulled back his slingshot and managed to kill two birds with one stone, we humans have loved achieving two (and if possible more) ends with one action.  For instance, it is helpful to remind staff that the CDD they do for AML reasons can also be “re-purposed” to meet CRM (customer relationship management) aims – in short, the more you know about a client, the more you can sell them.  And so it was with great pleasure that that I heard a couple of stories recently that showed how SARs, and indeed money laundering suspicion in general, can work double time.

The first was actually a missed opportunity.  Those who work in money laundering investigation are generally in favour of sharing information, but sadly the structure of the SARs regime – certainly here in the UK – is such that non-financial investigators do not have access to (or perhaps do not think to request access to) SARs information.  In a manhunt earlier this year, thousands of police officers were deployed to find a man suspected of murdering a young woman.  After they found him, it turned out that a SAR had been made on him by a money transfer business; they were uneasy about an online transaction he had made, and their SAR contained a huge amount of information about him, including his passport details and his IP address.  If only those looking for him had realised that all of that was on file…

The second is a more successful outcome – or at least it appears to be so at the moment.  Last week London police announced that they had arrested three Libyans, one of them on suspicion of involvement in the shooting of PC Yvonne Fletcher outside the Libyan embassy in London in 1984.  Eagle-eyed and bat-eared news followers will have picked up that all three are suspected of money laundering…  No doubt more will become clear as the investigation progresses, but surely it is not too much to speculate that a money laundering suspicion has led the police to these three people.  It would be far from the first time that a SAR had played a vital role in bringing a criminal to justice for crimes beyond his financial ones.

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