Guernsey Association of Compliance officers

Governance, Risk and Compliance in the Bailiwick of Guernsey

Quality of SARs Feedback

Adie Hale, Head of Financial Intelligence Unit, wishes to bring the below to the attention of GACO members. Individual emails will be sent out via THEMIS, however he has asked if we could encourage GACO members to take note of the contents and to disseminate them within their organisations, including at Board level.

The FIU has previously issued guidance on the quality of SARs which is also on their website.  They have also written to the Board of Directors of TCSPs, Banks, law firms and investment firms highlighting the need to have internal policies and procedures.

The FIU issued the below message via THEMIS yesterday and the feedback letters will start soon after. The attachment, "Why care about SARS" can be found here or under the Information & Research tab of GACO's website.

"Feedback to industry on the quality of SARs submitted to the FIU

The Financial Intelligence Unit (FIU) constantly monitors Suspicious Activity Reports (SARs) quality in order to ensure that it receives the best possible intelligence to enable it to perform its critical role in the fight against Money Laundering, Terrorist Financing and Proliferation Financing. In addition to the Guidance document on SARs available on the FIU website, the Head of the FIU also wrote to the Boards of banks, trust and company service providers firms (being the highest risk sectors identified by the National Risk Assessment) and also to law firms and investment businesses, drawing attention to the Guidance and the requirement to have internal policies and procedures on the quality of SARS being provided to the FIU.

As a result of its review, and in order to ensure consistent high quality in the submission of SARs, the FIU is introducing upgrades to the THEMIS system which will be effective later this year. Advice as to the upgrades will be issued in due course and the Guidance document will be revised to reflect the changes.

Meanwhile, as part of its continued provision of feedback to industry, the FIU will, with immediate effect, be giving initial written feedback on the quality of SARs and whether they align with the Guidance.This feedback will be given shortly after a SAR is submitted.

We take this opportunity to attach a document entitled “Why Care About SARs?”, which is by way of a reminder of the vital importance of this topic. Please circulate copies of this document within your organisation, including at Board level and to those who may be responsible for making an internal report to the MLRO."

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