December 7 2016 RJ Berry Director Financial Reporting Authority Agenda Statistics Feedback on SAR filings Q amp A Statistics 201516 Financial Year Receipt of SARs The Financial Reporting Authority FRA received ID: 794922
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Slide1
Cayman Islands Compliance AssociationDecember 7, 2016RJ BerryDirector, Financial Reporting Authority
Slide2AgendaStatisticsFeedback on SAR filings
Q & A
Slide3Statistics2015/16 Financial YearReceipt of SARs:The Financial Reporting Authority (FRA) received 620 suspicious activity reports (SARs) during the 2015/16 financial year, a record number of disclosures. It marked the first time that the number of SARs exceeded 600 and it was the third straight year that the number of SARs exceeded 500 (2014/15: 568 and 2013/14: 558).Banks continue to be the largest source of SARs (266 cases: 43%), followed by FIUs (75 cases: 12%), Money Services Businesses (72
cases: 12%), Company Managers / Corporate Services providers (
44
cases: 7%) and Trust Companies (
43
cases: 7
%).
Slide4Statistics2015/16 Financial YearReceipt of SARs:The five most common reasons for filing SARs were: (i) Suspicious Activity (345 cases: 56%); (ii) Fraud (115 cases: 19%); (iii) Corruption (62 cases: 10%); (iv) Money Laundering (34 cases: 5%); and (v) Regulatory Matters (16: 3%).
Slide5Statistics2015/16 Financial YearAnalysis and Dissemination of SARs:The FRA completed the analysis of 304 of the 620 new cases received during the Financial Year, leaving 316 in progress at year-end. Of the 304 new cases that were completed, 134 resulted in a disclosure, 119 were deemed to require no further immediate action, 48 were replies to requests from FIUs and 3 were replies to requests from local agencies.
The FRA also completed the analysis on
134
of 268 cases carried over from 2014/2015,
77
of 89 cases carried over from 2013/2014 and
32
of 33 cases carried over from 2012/2013, a total of
243
cases. Of the 243 previous cases that were completed,
155
were deemed to require no further immediate action,
75
resulted in a disclosure,
12
were replies to requests from FIUs and
1
was a reply to a request from a local agency.
Slide6Statistics2016/17 Financial Period (31 July – 31 October 2016)Receipt of SARs:The FRA received 183 SARs during the relevant period. Banks continue to be the largest source of SARs (76 cases: 42%), followed by FIUs (22 cases: 12%), Company Managers / Corporate Services providers (20 cases: 11%), Trust Companies (14 cases: 8%) and Attorneys (
13
cases: 7%).
The five most common reasons for filing SARs were: (
i
) Suspicious Activity (
72
cases: 39%); (ii) Fraud (
25
cases: 14%); (iii) Tax Evasion
(25
cases: 14%); (iv) Corruption (
15
cases: 8%); and (v) Money Laundering (
12
cases: 7%).
Slide7Statistics2016/17 Financial PeriodAnalysis and Dissemination of SARs:The FRA completed the analysis of 38 of the 183 new cases received during the relevant period. Of the 38 new cases that were completed, 23 resulted in a disclosure, 8 were deemed to require no further immediate action and 7 were replies to requests from FIUs.
The FRA also completed the analysis on
38
cases carried over from 2015/2016,
7
cases carried over from 2014/2015 and
2
cases carried over from 2012/2013, a total of
47
cases. Of the
47
previous cases that were completed,
2
0
were deemed to require no further immediate action,
20
resulted in a
disclosure and
7
were replies to requests from
FIUs.
Slide8Feedback on SAR FilingsWe will not advise you how to proceedNo Handwritten SARs!
Slide9Feedback on SAR FilingsCompleteness of Forms (Sections 2 and 3)Natural PersonsFull nameDOBID detailsNationalityLegal EntitiesFull nameJurisdictionSpecify the directors / officers / shareholders
Slide10Feedback on SAR FilingsSupporting documentationInformation relied on in making the filingRegister of Members / Directors and OfficersStatements
Slide11Feedback on SAR FilingsReason for Suspicion (section 5)It is a report regarding knowledge or suspicion of criminal conduct (as defined by POCL) – specify what you suspectTell us the complete story (we don’t have access to your systems and files)!Review periodDetails of transactions involvedAmounts involvedWhere funds came from or were sent to
Slide12Feedback on SAR FilingsReason for Suspicion (section 5)Inconsistent activity with client profile – tell us what the profile isSteps taken by the SAR filerQuestions / discussions with client Enhanced monitoring?How it impacts you Intention regarding the client relationship
Slide13Q & A