Failure to report

Unsure whether to go ahead with a transfer of funds for a high net worth client, something doesn’t feel right to the MLRO in London, who opts to file a consent SAR. A standard part of the reporter’s day job, maybe, but at the same time consent requests have proved a growing source of frustration for the UK’s financial intelligence unit (UKFIU) in the National Crime Agency (NCA), which is required by law to revert with a notification to hold off any transaction within seven working days. In a September 2014 circular to reporters [1], the NCA notes that turnaround time for responding to consent SARs has “seen a significant increase” on previous years – it stood at an average of 3.5 days in the year to September 2013 [2]; this, it says, is due not only to a rise in volumes and inherent complexity in some requests but also to a fall-off in quality.