On 16 November 2016, the UK government’s Home Affairs Select Committee concluded its examination of the UK’s proceeds of crime regime by publishing the government response to the fifth report of the committee in the form of an appendix to that report. (I know, I know, but as I read it, this is the end of the matter and contains the final word on which will be done with regard to proceeds of crime.) There’s plenty of meat in the appendix, but one teeny little thing did catch my eye.
One of the issues raised, discussed, considered and then pronounced upon by the committee is that of SARs and – specifically – the suitability or otherwise of ELMER (the National Crime Agency’s SAR database, named after Elmer Irey, the IRS agent who led the successful tax evasion prosecution of Al Capone). Evidence given to the committee confirmed that ELMER “is heavily overloaded and therefore rendered completely ineffective”. The solution, naturally, is to “replace ELMER with a robust system for handling Suspicious Activity Reports”, and moreover to “involve those who actually use the SARs system to make reports – as well as those charged with investigating at the other end – in designing the replacement to ELMER”. So far, so sensible. But then this little comment is made: “The Government has committed to replacing the SARs IT system, and considers that those who will benefit from the new IT system should share the costs for developing it.”
Now, I am battling a rather nasty cold today and my head may be fuzzier than usual, but do they mean us? The regulated sector? Or do they mean the police forces? Or the foreign FIUs? Or the general public – as surely the reduction of instances of money laundering will be beneficial to all? If anyone knows exactly what is meant by “those who will benefit from the new IT system”, please leave an explanatory comment, as my piggy bank and I are rather worried about it.
I hate money laundering 