http://www.theregister.co.uk/2005/10/13/uk_sars_report/
 

Lots of data, but police can't or won't use it fully

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By John
<http://forms.theregister.co.uk/mail_author/?story_url=/2005/10/13/uk_sars_r
eport/> Lettice
Published Thursday 13th October 2005 13:26 GMT
As you prove your identity ("I'm sorry sir, but it's a legal requirement")
to your bank for the umpteenth time, no doubt you wonder whether the
mountain of data that money laundering rules produce is of the slightest use
to the people with access to it. Well, wonder no more - the second critical
study on the use of Suspicious Activity Reports (SARs) in two years
concludes that SARs are under-utilised by most Law Enforcement Agencies
(LEAs), and also reveals that pending the implementation of (uh oh...) a new
database system, many of them aren't being used at all.
The study was commissioned by The Association of Chief Police Officers and
funded by the Home Office, and although author Matthew Fleming, Research
Fellow at the UCL Jill Dando Institute of Crime Science, appears to have
completed it in June, for some strange reason it seems not to have been
published until the other week. It reveals a system that LEAs are
ill-equipped (and frequently disinclined) to use, and a growing mountain of
data that really is not being dealt with systematically. And although
Fleming is guardedly hopeful about the new database 'fix', there are enough
caveats attached for one to doubt that use of SARs will improve dramatically
in the near future.
Suspicious Activity Reports are sent initially to the National Criminal
Intelligence Service, under anti money-laundering legislation, by companies
in the financial sector. They're intended to provide LEAs, Customs and the
Inland Revenue with signs of suspicious activity that might indicate
laundering and/or terrorist financing operations. A lot of what comes
through will of course be guff, but there will be good data in there as well
which could flag up people and operations you didn't know about. If, that
is, you're capable of sifting out the good data.
Government claims to be cracking down on, say, terrorist finance tend not to
mention that the crackdown can be a little bit random and not particularly
extensive. But that's about the size of it - the Government's thirst for
data is running well ahead of Government technology's ability to deal with
it (and one could reasonably speculate that this will apply equally to
numerous other ongoing data grabs).
The handling of SARs has been through a couple of different regimes in
recent years. Prior to the publication of the previous study on their use
(by KPMG, in July 2003), they were given a preliminary sift by NCIS so that
those likely to be of interest were sent to the interested LEA, and the rest
sent out to the relevant LEA by postcode. The Inland Revenue, Customs &
Excise and the Terrorist Finance had staff at NCIS combing the database, but
the bulk of SARs were sent out by email in "LEA Packs" in .CSV form. So the
system identified transactions by individuals it was already suspicious of,
while transactions by people who hadn't already tripped a wire would be
likely to go out in the big, general pile.
For the year after the publication of the KPMG study NCIS assessed all SARs
on a qualitative basis and sent out those it deemed to be of interest to the
relevant LEA. The raw data sent out should therefore have become more
attractive to LEAs because a higher proportion of it was likely to be
useful, and the volume of data received was smaller. SARs not thought to be
of interest were not thrown away, but held in the database, Elmer, which
could be searched by request.
Elmer seems likely to have influenced what happened next. In June 2004 NCIS,
without consultation with LEAs, significantly reduced the volume of SARs
sent out, and encouraged LEAs to submit Elmer search requests. NCIS said
that "the reactive, one by one allocation process risked not revealing the
most capable and most prolific of money-laundering suspects and not
highlighting patterns and typologies."
But the move could also have been a reaction to the continuing failure of
LEAs to use SARs effectively, and may have been made in anticipation of the
rollout of the next version of Elmer. This had originally been planned for
autumn 2004, a few months after the change in NCIS practice, but slipped
into 2005. The system did go into pilot in February, and was scheduled to be
rolled out in May 2005. It's not clear if this has actually happened, and if
so to what extent, but at best this will mean that a year's supply of
non-prioritised SARs will be of largely historical interest.
 


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