99% of SARs are given consent.
26/06/2023
A colleague of Comsure attended the JFSC, JERSEYGOV & JFIU hosted DNFB fighting financial crime event on 13th June 2023. The full slide deck is here.
- https://www.jerseyfsc.org/media/6703/dnfbp-event-13-june.pdf -
- FIU slides are attached here
What our colleague reported is as follows:-
Although I can’t remember exactly what was said and it was probably a bit of a throw-away comment, but I think it was Jonathan Groom around slide 47 [full deck] talked about SARS and consent.
What I took away from what was said was.
- That about 99% of SARs are given consent because they appreciate the seriousness and effect of no consent amounting to an informal freeze.
At first blush this number seems ridiculously high and encouragement for defensive reporting 99% however on further investigation seems consistent with what was said in:-
- A Jersey judgement - Prospective Applicant v the Chief Officer [See paras 37 of Prospective Applicant – also extracted below]
and
- Advocate Redgrave’s article. 13/01/2022 Indefinite informal asset freezes – the beginning of the end? – see extract below.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.