ICAEW and The International Federation of Accountants (IFAC) have produced the next instalment of their Anti-Money Laundering: The Basics educational series, Tools to Fight Back. This instalment covers enhanced due diligence (EDD) and how to file effective and actionable suspicious activity reports (SAR).
The series aims to help accountants enhance their understanding of how money laundering works, the risks accountants face, and what they can do to mitigate these risks and make a positive contribution to the public interest.
Alongside EDD and SARs, the instalment also covers Finance Intelligence Units.
Suspicious Activity Reports (SARS)
The document provides useful guidance on the content of SARS. It is recommended that when submitting SARS, professional accountants should adopt the “three Cs” approach – all SARS should be clear, concise and with a clear chronology, for example:
- Who is conducting the criminal or suspicious activity
- What the suspect is trying to do or has done to cause suspicion
- The date or dates it occurred
- Where the suspicious activity took place
The instalment goes into detail as to how to present this in an effective way.
“As trusted advisers and sophisticated finance professionals, accountants have a key role to play in the fight against crime and subsequent attempts to launder the proceeds of criminal activity. Where they have suspicions, it is important that professional accountants provide timely and relevant useful information to NCAS, so that law enforcement can identify overall trends and take appropriate action,” says David Gomez, ICAEW’s Senior Lead, Ethics.
Anti-Money Laundering: The Basics is featured on both the IFAC and ICAEW websites. It is available to download for free. To be globally relevant, the series uses the risk-based approach of the Financial Action Task Force (FATF) – the global money laundering and terrorist financing watchdog – as a starting point.