EU- SARS/STRs - How useful are they when ONLY 1.1% of the criminal profits are confiscated.
04/08/2023
Jersey operates a SUSPICIOUS ACTIVITY REPORTING regime rather than suspicious transaction. The main difference between the two is the object of suspicion.
- SARs focus on the activity and whether that is suspicious.
- STRs focus on actual transactions.
It is noted that the filing of a SAR is not demonstrative of ML in itself, only that a suspicion had arisen. This aligned with the data from the 2021 Europol report, From Suspicion to Action, which found
- That only 10% of suspicious transaction reports 16 led to further investigation.
Further It is alarming to consider, that even where further investigated, the likelihood of successful asset recovery is low. Europol findings show that from 2010 to 2014,
- Just 2.2% of the estimated proceeds of crime were provisionally seized or frozen, and
- Only 1.1% of the criminal profits were ultimately confiscated at EU level
- https://www.europol.europa.eu/media-press/newsroom/news/does-crime-still-pay
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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.