Video: Why quality Suspicious Activity Reports matter
Claire Wilson (CW): I’m Claire Wilson. I lead on the anti-money laundering and counter terrorism financing strategy for the Gambling Commission. I worked for the Commission for 11 years and prior to that I worked in the gambling industry for 15 years.
These videos are being jointly made with our partners at the National Crime Agency. Let me introduce my co-host, Tony Fitzpatrick from the National Crime Agency who will in a moment explain the wider benefits to the UK as a result of enhancing the quality of your SAR reporting.
Tony Fitzpatrick (TF): Hi everybody. My name is Tony Fitzpatrick, I’m from the UKFIU, the National Crime Agency and I’ll go into discussing with you shortly why getting the quality right in SARs is so important.
CW: Thanks Tony. So, this video continues the series we will be releasing throughout September 2018 and focuses on why getting the quality of SARs submitted is important, and we’ll show to you why the Commission wants to raise standards across the gambling industry.
Operators are already submitting good quality SARs and we want to maintain that quality and improve where we can.
So, Tony why is it so important to get the quality of SARs submission right?
TF: Getting the quality right is very important. It helps data matching so that SARs can be fast-tracked to the right people, it saves time and money to everybody involved.
Getting the right quality SAR has a big impact in helping criminal investigations. It helps get the money back off the bad guys, and where possible, getting money back to the victims.
Good quality SARs prevent all sorts of serious crime, including money laundering and terrorist financing.
I’ll deal firstly with data matching and I want to dispel the myth that SARs go into a black hole, they don’t. Every single SAR is data washed against a number of other databases.
To exploit the information in a SAR, it is washed or matches against a number of other databases and this also helps drive the SAR aging process.
For example, the information within a SAR, if it’s correct, helps us manage quickly and swiftly defence against money laundering, helps us process those DAMLs, defence against money laundering requests very quickly. That process is reliant on having basic standards of information.
It’s very important that we’re able to confirm exact matches of people. Such things are normally done though things that we would call personal identifiers, such as the name or names of a person, the date of birth. The address is also very crucial, and all these things should be put in a SAR, if it’s known to the reporter.
In most cases, through your due diligence and know your customer requirements, most of these factors, these identifiers, should be known and you should put them in a SAR. Quality SARs help with our prioritisation, they help us fast-track and help us conduct a range of analysis to identify new trends, new emergent threats.
A good description of the reasons for suspicion with a glossary code is very important. If we can all continue to improve the quality of SARs, then we in the UKFIU can deal with them more quickly and succinctly.
Overall, a good quality SAR helps detect and prevent crime. Some gambling sector SARs play a significant role in helping law enforcement start investigations and help bring about the prosecution of organised crime groups who abuse industry systems.
Organised crime groups not only traffic drugs and people, they enforce their criminal activities by using violence, by using guns and knife crime. The criminal gangs therefore cause considerable harm and misery to numerous local communities.
Gambling sector SARs help combat the impact of this criminal behaviour and also help protect vulnerable people. An example of a gambling sector SAR was where it helped combat an organised crime group.
The SAR was submitted and a result of the information a number of individuals who identified as being involved in trafficking cannabis, and also through the gambling SAR, it was also identified that these individuals had no legitimate means of income, and in the head of this crime group had deposited about £1.8 million into a casino account over four years.
As a result of that gambling sector SAR 9 people were arrested and convicted and received custodial prison sentences. Also, a number of confiscation hearings took place where considerable amounts of money was recovered, and some of that would have been returned to victims.
Another example of when a gambling sector SAR helped detect an offence of crime was one relation, one relating to a romance fraud where there was a number of vulnerable people exploited.
A number of SARs was put in about a particular individual, but one particular SAR from the gambling sector was the last piece in the jigsaw and it identified an individual involved in a number of fraudulent credits. This individual was placing significant amounts of money in and out of gambling accounts.
The suspect was eventually arrested for dishonestly making false representation and he was found to have benefited by about £1 million, when he had tricked a number of females. He befriended them and convinced them that he needed certain amounts of money to avoid being attacked by other people and also as a way of getting money from getting money dishonestly.
It was found that he drained every single penny he could from one victim before he moved on to the next victim. That gambling sector SAR helped arrest that person and prevented him from hurting other individuals in the future.
Some gambling sector SARs are crucial in identifying professional enablers. The gambling sector has a very robust and comprehensive level of vigilance concerning assessments of customer lifestyles.
The overlapping of the occupational status and the visible lifestyle helps identify criminal activity. It helps identify those corrupt professionals who abuse their clients or help facilitate money laundering using their specialist knowledge.
It is always helpful to clearly state the occupation of subjects in your SARS and where known, what type of professional service they provide or what trade body they belong to. An example would be:
“we know the subject is solicitor who is providing legal advice for buying or selling houses”
or another example might be:
“we know this person is an accountant who’s registered as a chartered accountant and he deals with importing and exporting account”.
Another example exists were such was these SARs that really help law enforcement arrest and detect people that are using their professional skills for dishonest purposes.
A gambling sector SAR relating to a solicitor who was using client funds for gambling activity. The SAR was referred to the Solicitors Regulatory Authority, who took action and closed down the firm. So, it’s not always about arresting and charging people, it’s also about disrupting them from their normal activities.
SARs may not always instigate a new investigation, but every SAR matters and your SAR could be the final piece in the jigsaw.
There are SARs out there in the past that identified people that have been involved in all sorts of horrible crimes. Things like organ trafficking, also human trafficking, modern slavery. Also, SARs in the past have helped to identify people responsible for rapes and murders, not only in the UK, but also abroad.
A good quality SAR helps law enforcement improve and get a richer intelligence picture for their criminal network analysis, and to be honest, helps in all sorts of serious crimes.
A good example would be, last year there were a number of instances in the UK in relation to terrorist attacks. SARs from all sectors including the gambling sector helped police investigate those terrorist investigations.
Also, we’ve had a number of nasty, horrible instances take place where SARs also helped out in a different way, for example; when we had that horrible fire at Grenville tower in London a number of SAR and SAR reporters helped sift through information to identify some of the victims and relatives involved in that fire.
So, to sum up I’ll outline the benefit of good quality SARs.Good quality SARs, as I said right at the beginning of this presentation, help data matching and criminal network analysis. They help prevent and detect money laundering and other serious crimes.
If we get it right the first time everybody saves time and resource. They help UKFIU and law enforcement prioritise and exploit the information. They help in particular UKFIU to have a fastest response possible for their defence against money laundering processes. They help analysis, they help identify new trends, they help identify patterns and typologies.
All these typologies and all these patterns and trends can be fed back to you, the reporter, and help you with red flags, help you through your risk assessments and help you with your risk profiles. So overall, the SARs have a number of benefits and if we get it right first time, as I said, we will all save time and money.
I can vouch for the SARs; I can vouch for their benefits. I was a police officer for 30 years and I investigated a number of murders and rapes, financial intelligence with SARs helped me solve those crimes.
I worked in C-OP – child exploitation and child abuse and again financial intelligence from your SARs, helped me save and rescue children from being abused. I used to head Human Trafficking Centre for its operations in the UK and abroad.
A number of SARs had vital information that helped me rescue a number of victims from human trafficking and modern slavery, and more recently now, I can see from working UKFIU for the last 5 years, your SARs are making a real impact and making a big difference. And that’s why we need to make sure that every SAR we put in is the best quality possible.
CW: Ok, thanks Tony. So, thank you for watching this video and make sure you look out for the next instalment in September, where we will focus on getting the right quality in your general SAR reporting.
And don’t forgot to go and take the survey on the Commission’s website around your understanding of the SARs reporting system.
Thank you for tuning in.
TF: Thank you, bye bye.